Where is “None of the Above”?

While we applaud the public being invited to contribute, we’re forced to choose between values we may not agree with. Anyone who believes dogs in a puppy farm should get more than 30 minutes of human interaction per day is unable to indicate that. The results of the survey are going to be misleading when it only captures a narrow band of values.

Victorian Government is seeking public input on what minimum standards should be imposed on dog breeders. We believe the options provided will seriously the results of the survey.

It will not be obvious to all participants that they can continue without selection an answer. At a bare minimum each question should include ‘none of the above’ or “i don’t know” so users do not feel forced to indicate an option they don’t agree with.

What Should Be Done?

A new valid survey should be created that will capture data more accurately. The question above should at least have a “more than 30 min” option.

• Existing data should be discarded for the current survey
• Invitations should be sent out for people to participate in the new valid survey

With just under two weeks till the opening of  ‘dog season’ in Victoria, Councils are preparing to start knocking on doors and seizing family pets.

The State Government is encouraging the public to dob in their neighbours pets via a dedicated ‘Dob in a Dangerous Dog’ hotline.

Q. My neighbour has a pit bull terrier that does not appear to be
registered or kept according to the law. What can I do?

A. Call the Local Council or the Government hotline (1300 101 080). An
Authorised Officer will inspect the premises and review the breed of the dog.
If it is of a restricted breed then an official declaration process and
restriction of the dog will be initiated.

Restricted Breed Dogs FAQ - Bureau of Animal Welfare - Department of Primary Industries, Victoria

DPI Advice to Councils is Incorrect

Council staff are not qualified to identify the breed components of dogs from unknown parentage. The identification “standard” issued by the State Government comes without explanation of how it is to be used. It will lead to mistakes and declarations of dogs who do not have any Pit Bull in them because there is no scientific basis behind it. New laws grant Councils power to kill dogs based on their appearance under certain (but not all) circumstances.

The DPI’s own website states:

Current owners may keep their restricted breed dogs as long as the dogs were:

1. in Victoria prior to 1 September 2010, AND
2. registered (as any breed) with the local council prior to 30 September 2011.

Things You Should Know About Restricted Breed Dogs – Victoria DPI Website

The DPI have provided advice to Councils on the process for declaring a Restricted Breed Dog. It wrongly gives the impression that unless the owner makes an application to VCAT to appeal the declaration their dog will be killed. As we saw above, that is not always the case. Owners who meet the conditions can accept the declaration and may be allowed to keep their dog subject to restrictions.

Restricted Breed Process Flow Chart distributed to Councils by Victorian DPI

We’re talking about the seizure and destruction of family pets. Dog owners will have their lives turned upside down by what’s about to occur. It’s crucial that Council staff and dog owners are given clear and accurate information.

"There is no scientific methodology or process for determining the
genetic history of a dog from its physical appearance."

Linda Watson, Researcher

"If it looks like a Pit Bull, it's a Pit Bull"

Graeme Smith, CEO at Lost Dogs Home

Owners Fear Their Dogs Will Be Wrongly Identified

An increasing number of Victorians are currently terrified that their family pets will be seized and killed by Council Officers. The Victorian Government wants to rid the state of ‘Pit Bulls’ and has enacted new laws to enable a cull. These laws enable Council officers to seize and kill dogs they believe look like American Pit Bull Terriers.

Breed Standards Not Valid For Identifying Breed

Key to this process is the release by the Minister of the ‘Standard For Restricted Breed Dogs in Victoria’. As we will see below, this is basically a rearrangement and rewording of the official breed standards for the breeds in question. The problem is, breed standards are intended for dog show judges to use when comparing dogs of a known pedigree.

Use of a breed standard as a basis for determining the breed of a dog, where that
breed is not known as a matter of fact and  is a question in dispute, is an entirely
misconceived use for the document, and is not a process which is capable of
producing any objectively valid determination as to whether a dog is of one particular
breed or not.

VALERIE HODGSON, DINO DA FRE Complainant AND LOGAN CITY COUNCIL

That Won’t Stop This Government

The Minister has released an identification standard (download here) created by three individuals who we believe wish to remain anonymous. The work they have produced has not been scientifically validated. No evidence has been provided to allay fears that it will produce false positives. Given its intention is to decide the fates of family pets this is unacceptable.

Thinly Veiled Copy of UKC Breed Standard

Did you ever do a school project by copying text from a single book and simply rearranging sentences and making cosmetic changes to avoid accusations of plagiarism?  The authors of our ‘approved standard’ appear to have done just this. The section on American Pit Bull Terriers reads like a thinly veiled reworking of the United Kennel Club’s breed standard for APBT’s.

Muzzle

Slightly shorter in length to the skull (i.e. 2:3 ratio for muzzle:skull). It is broad, deep and powerful with a slight taper to the nose and falls away slightly under the eyes (refer figure 4).

UKC: The muzzle is broad and deep with a very slight taper from the stop to the nose, and a slight falling away under the eyes. The length of muzzle is shorter than the length of skull, with a ratio of approximately 2:3.

Skull

Large, fairly flat, broad and deep, slightly tapering towards the stop. There is a deep median furrow reducing in depth from stop to occiput. Cheek muscles are prominent but free of wrinkles. When the dog is alerted wrinkles will form on the forehead.
UKC: The skull is large, flat or slightly rounded, deep, and broad between the ears. Viewed from the top, the skull tapers just slightly toward the stop. There is a deep median furrow that diminishes in depth from the stop to the occiput. Cheek muscles are prominent but free of wrinkles. When the dog is concentrating, wrinkles form on the forehead, which give the APBT his unique expression.

Nose

Large with wide open nostrils and may be of any colour.

UKC: The nose is large with wide, open nostrils. The nose may be any color.

Eyes

Medium in size, round in shape and set low in the head – not prominent. Eyes can be all colours except blue. The eye rims are the same colour as the skin colour.

UKC: Eyes are medium size, round to almond-shaped, and set well apart and low on the skull. All colors are equally acceptable except blue, which is a serious fault. Haw should not be visible.

Neck

Moderate length and with great strength, tapering from the head into the shoulders. A slight arch over the crest. The neck must be free from loose skin or dewlap (loose, pendulous skin under the throat).

The neck is of moderate length and muscular. There is a slight arch at the crest. The neck widens gradually from where it joins the skull to where it blends into well laid-back shoulders. The skin on the neck is tight and without dewlap.

Mocking A Dog Before Killing It?

The breed standard contains photographs of a number of dogs. We’re seeking more information about these dogs but think there’s a reasonable chance they were taken at a Victorian pound and that these dogs were subsequently killed.

Both collars look super loose and the second “tough dog” collar was obviously dropped over the top of the slip lead. To make him look vicious? Was this his crown of thorns?

Are These Verified American Pit Bull Terriers?

Are they certified American Pit Bull Terriers or are they simply dogs someone thought looked like Pit Bulls? How was the breed of these dogs established? This document will be given to people with no training or qualification in breed identification. Surely it does not include images of dogs from unknown parentage?

Who Actually Wrote The Standard?

People do some things under the clover of anonymity that they would never dream of if they had to sign their work. It’s our understanding that the authors were assured their involvement would remain a secret.

Hon. P. R. HALL (Minister for Higher Education
and Skills) — In respect of consultation with other
groups, I can advise Mr Barber that the persons
involved in the consultation on the development of the
standard — I do not know the actual names of the
people — included an all-breeds judge, a veterinarian
and an authorised officer of council. They represented
their groups on the development of the standard.

Hansard

We Believe The Writing Group Consisted Of These People

We would welcome a response from the writers and would be happy to publish anything they send through.

Patricia Stewart, AVA Victorian Branch

Glenda Cook, All Breeds Judge and Corgi Breeder

An Authorised Officer

The primary means of breed identification for non-pedigreed dogs and mixed-breed dogs is a visual glance and a guess. The dog may be compared with the breed standard for a breed; again, this is based on visual assessment. It is entirely subjective.

http://stopbsl.com/bsloverview/impossibleid/

Domestic Animals Amendment (Restricted Breeds) Bill 2011 Passed

I’ve just returned home from Victorian Parliament where a new Bill has been rushed through both Houses without being included in the Notice papers.

The Domestic Animals Amendment (Restricted Breeds) Bill empowers the Minister to approve “standards” by which an Authorised Officer can declare your dog a Restricted Breed Dog.

One year ago tomorrow the Domestic Animals Act was updated to enable “a standard prescribed by regulations” to be used. What’s changed now is that the definition of what constitutes a ‘Pit Bull Terrier’ is at the whim of the Executive with no ability for the Parliament to reject changes.

As Greens Minister Greg Barber put it, the Minister could draw a stick figure of a dog, approve it and therefore enable rangers to seize and kill and dog that fits that description that was not in Victoria prior to 1 Sep 2010.

The opposition, while not opposing the Bill, pointed out that the Governor in Council could have provided an exemption from the requirement to produce a regulatory impact statement. This could have epedited the process without removing Parliamentary oversight.

“an approved standard”

The Minister was asked how we could trust that such a ‘standard’ would not result in innocent dogs being wrongly identified as ‘pit bull crosses’. If the standard is too broad it would end up including dogs with no ‘pit bull’ in them that share similar physical characteristics. This would have serious consequences given Councils would be required to kill many of these dogs.

Parliament was told that the approved standard would be reliable because it was created by a working group that consisted of:

* one ‘all breeds’ judge
* one Authorised Officer
* one Australian Veterinary Association Official

The Minister went on to say that,

“Following the 2010 legislative amendment the working party consisted of a veterinarian who previously participated in the then minister’s restricted dog breed panel and was on the executive of the Australian Veterinary Association.”

spoken by Hon. P. R. HALL - Hansard

He seemed very proud to be able to claim that not only was there a dog catcher and someone out of ‘best in show’, they had someone with relevant qualifications.

What’s Motivating This Vet?

The Australian Veterinary Association (along with RSPCA Vic) opposes Breed Discrimination. Why would an AVA Official assist in creating this ‘standard’? Is it the same AVA Official who presided over the Restricted Breed Review Panel that led to Ouzie being killed by Manningham Council? How can the AVA allow this?

Patricia Stewart presided over the Review Panel that led to Ouzie being killed.

Despite the RSPCA making their position clear to the Minister, Peter Walsh prefers to remember what Hugh Wirth said in 2009. “The president of the RSPCA is on the public record as well in believing that this type of dog has no right to exist as well,” he said. Let’s see what Hugh Wirth had to say about this in 2010.

Minister Peter Walsh was recently happy with current laws

“I think we’ve actually got it fairly right at the moment so I don’t anticipate there being any changes”. Tune in from 2m40s to hear a prophetic interview with the Minister recorded several weeks before the Herald Sun Ayen Chol died and the Herald Sun started their #banthebreed campaign.

The Australian Veterinary Association Opposed Breed Bans

Despite having some of the most restrictive rules for dog owners in the world, dog attacks still happen in Australia. Vets say overregulation is not the answer.

“Following the tragic dog attack in Melbourne this week it’s vital that we redouble our efforts to improve education and socialisation of dogs and people,” said Dr Kersti Seksel from the Australian Veterinary Association (AVA).

“It’s understandable that people are now calling for the banning of some breeds, however all the good evidence available shows that this doesn’t work,” she said

“Unfortunately we believe the banning and overregulation of dogs in our communities could be part of the problem as this leads to poor socialisation and increased risk of attacks.

http://www.ava.com.au/mediarelease/vets-say-ban-deed-not-breed

So Who Is Supporting Breed Bans?

This clown again.

In June 2011 I was contacted by the ABC to give comment for a story about the Cat Protection Society of Victoria. I agreed and they sent a reporter and camera operator out to to my place on the same day. About a month later I received an email to say the story would go to air on Friday 12 Aug.

Surprised to See RSPCA Vic Alongside LDH & CPS

I expected the story to be focused on claims the CPS had been misrepresenting its statistics to the public. The story ended up focusing largely on claims that the No Kill movement were “waging a cyber war” against the RSPCA, Lost Dogs Home and Cat Protection Society of Victoria. I was surprised to hear RSPCA Vic being lumped in with LDH and CPS when they are leagues apart.

Animal Advocates are Working With RSPCA Vic

The story incorrectly stated that animal advocates have been attacking RSPCA Victoria. The exact opposite is true for the simple reason that they are working steadily toward reducing their kill rates.

• Their annual reports (including statistics) have been available on their website for many years now
• Their foster care program saved over 600 lives in 2010
• They respond promptly to all (reasonable) questions on their Facebook page
• They emptied their catteries last year with an innovative ‘adoption fee waived’ promotion
• Their ‘Twilight Adoption’ extended hours make it easier for people to adopt
• They are open all day on weekends

"I see the No Kill activists as leading the way and that's the same with any social change."

Lost Dogs Home Are In The Doghouse

The Lost Dogs Home does not have many friends in animal welfare.

• They reported a live release rate of just 14.2% for cats in 2010 (compared to 40% at RSPCA)
• They won’t tell us how many animals were fostered in 2010
• Their annual reports (including statistics) were not made available to the public till 2010
• They remove reasonable questions from their Facebook page and ban people who ask them
• They close at lunchtime on Sundays and public holidays

"They are cyber bullies because they're on the Internet trying to create controversy."

My Comments Were Not Directed At RSPCA Vic

I was interviewed about CPS, not RSPCA Vic. I have assisted them over the last couple of years and just last week attended their annual Seminar. I have no idea who told the producer that “the No Kill movement” were attacking RSPCA. Could it have been one of the other two shelters mentioned? It wouldn’t be the first time they let a reporter say something incorrect.

"The problem with allowing these people to be the public face of animal welfare is that they're holding back change and they're keeping us stuck in a 20th century kill model."

Stay Tuned For More On Cat Protection Society

There’s a lot more to this story. Out of the 166,000 viewers on Friday night, many will know someone who has worked there and may be able to shed more light on what goes on there. Expect to hear more over coming months.

Science To The Rescue!

A few years ago a research paper entitled “What Happens To Shelter Dogs” was published that compared the outcomes for animals from three Melbourne shelters. These were:

• The Lost Dogs’ Home, North Melbourne [City Shelter]
• RSPCA, Burwood [Suburban Shelter]
• Animal Aid, Coldstream [Rural Shelter]

Could They Be Killing Dogs To Reduce Costs?

In 2010, only four out of every ten unclaimed dogs were offered for adoption at The Lost Dogs’ Home. How do they choose the unlucky ones? In Victoria, pounds and shelters are required by law to ensure all animals are desexed before sale. Desexing a male dog is generally less costly in both time and resources than desexing a female. Of course, picking out dogs who were are already desexed would offer the biggest saving.

Study Shows LDH Killing Females at a Higher Rate

At the city shelter, bitches were euthanized almost twice as frequently
as at the other shelters, χ2(6, N = 8,883) = 693.72, p < .0001, although
males were euthanized at about 1.5 times the frequency of other shelters,
χ2(6, N = 11,846) = 816.02, p < .0001.

Study Shows LDH Killing Sexually Entire Animals at a Higher Rate

Sexually entire animals formed approximately 66% of animals euthanized at
the rural and suburban shelters but a highly significant 91.7% of
those euthanized at the city, χ2(2, N = 6,539) = 594.72, p < .0001.

Do The Lost Dogs Home Still Selectively Kill Dogs Based on Sex, Size and Sexual Entirety?

We’re repeatedly told that LDH only kill dogs who are untreatably sick or injured or are too aggressive to be rehomed. It’s farcical to suggest that 60% of unclaimed dogs fall into these categories and there is no evidence provided to support their claims.

On the contrary, these dogs are hidden from public view from the moment they are impounded until the day they are sent off in body bags. The Lost Dogs Home has refused calls for them to post pictures of impounded dogs on the internet. This common practice make it easier for owners to locate the pup but would lift the veil of secrecy around their “processing” of unclaimed dogs.

The Question Lost Dogs Home Wouldn’t Answer

I’d been corresponding with LDH for around six months until one day in March, 2011 when I posed the following question:

In the year to 30 June 2010,

• how many dogs and how many cats were surrendered by owners to LDH?
• how many of the dogs received, reclaimed, rehomed or destroyed were sexually entire on entry?

28 April 2011

Code Review Project Officer

Bureau of Animals Welfare

475 Mickleham Road

ATTWOOD  Vic  3049

By Email:  animal.welfare@dpi.vic.gov.au

Dear Sir/Madam,

Good For Dogs Submission on

Code of Practice for the Management of Dogs and Cats in Shelters and Pounds (Revision 1)

While we welcome the removal of the ’28 Day Rule’ it is obvious the writers of this draft haven’t absorbed the message that resonated so strongly during the campaign for its removal. Shelters should not be forced to make bad decisions based on an overly prescriptive set of rules that are blind to circumstance. We reject the imposition of arbitrary limits and restrictions that result in the unnecessary killing of cats and dogs in our pounds and shelter. We expect animal welfare laws to be supported by sound animal welfare science and not just the musings of a few industry representatives.

Rules need to allow for discretion. Discretion calls for the ability to review decisions and audit results.

There are numerous examples in the Code where those working to save a life are restricted by an arbitrary rule with no situational discretion allowed. The Code sets the maximum allowable period for an animal to be in foster care to three months. There is no process for appeal and record keeping requirements mean that any breach could be detected during an audit.

Conversely the Code gives those wishing to kill an animal a great deal of discretion, with little opportunity for appeal or audit. An example of this is in the assessment of an incoming cat as unidentifiable and wild/uncontrollable/diseased. This cat can be killed immediately, eliminating the possibility for a review that may detect incorrect assessments. An audit would not detect abuse as any evidence is destroyed.

We have included a detailed criticism of the draft but would like to highlight some of our objections to the restrictions on foster care programs run by pounds and shelters. The following arbitrary rules do not allow for individual circumstances and are not supported by animal welfare science:

• not allowing healthy adoptable animals to be placed in pound/shelter run foster care
• arbitrary 3 month limit on time animals can be fostered
• requiring audits by authorised officers of foster carer’s homes
• weekly vet visits regardless of whether they are required

We believe the process that produced this draft of the Code to be deeply flawed and recommend the Minister conduct a review into how other jurisdictions regulate Pounds and Shelters. We argue that over regulation stifles innovation with unintended consequences often  having the opposite effect to those originally envisaged.

1.1 Proprietor

Moving responsibilities from the operations manager to the proprietor of an establishment will provide a disincentive for Councils to run their own in house service as Council CEO’s will not want to be responsible for things such as “the health and well-being of all animals in the establishment and in foster care”.

>1.2 Operations manager

It’s not clear what experience or qualifications in the husbandry of dogs and cats an operations manager must have.

1.3 Animal attendants

There is no evidence a 20% increase in attendant labour is required.

1.6 Foster Carer

The Code defines the minimum conditions for pounds and shelters and is enforceable. These conditions apply to foster carers and do not belong in the Code as they are outside of the control of the establishment.

2.2 Admission

There are insufficient safeguards against cats being misclassified. Not enough is done to prevent failed microchip scans, the term ‘diseased’ is too vague, and many pet cats could be described as ‘uncontrollable’ if trapped and delivered to a pound.

2.3 Vaccination

Should make clear that animals for which a record of vaccination exists or for which titre testing indicates immunity should not be required to be re vaccinated.

The AVA’s policy refers to the World Small Animal Veterinary Association’s (WSAVA’s) Guidelines for the Vaccination of Dogs and Cats, which state that

“Vaccines should not be given needlessly.  Core vaccines should not be given any more frequently than every three years after the 12-month booster injection following the puppy/kitten series”

The APVMA advises that antibody titre testing is available to determine if an animal needs re-vaccination.

2.5 Isolation

“All animals confined in isolation housing must be under the supervision of a veterinary practitioner and the fate of an animal must be decided by a veterinary practitioner.”

Vet’s provide advice. It’s up to the establishment to decide who has the final say on the fate of an animal, especially establishments without an in house vet.

2.8 Foster care

“The only time an animal can be placed in foster care is on the grounds of juvenile, veterinary rehabilitation or behavioural rehabilitation foster care.”

There is no reasonable justification to exclude all other grounds for placing animals into foster care.

“Foster care must only be undertaken with the signed approval of a veterinary practitioner. The veterinary practitioner must ensure that the animal is suitable for foster care and sign the animal’s records endorsing such approval.”

This only seems justified for veterinary rehabilitation foster care.

“A health plan determined by a veterinary practitioner must be provided for each animal being placed in foster care.”

This only seems justified for veterinary rehabilitation foster care.

“Where, in the veterinary practitioner’s opinion, the animal’s progress is such that they believe the animal may not sufficiently improve in the maximum period allowable to enable the animal to be rehoused, the animal must be returned to the establishment.”

It should not be mandatory to terminate a foster care placement simply because a veterinarian believes the animal may not be ready for rehoming by the end of a maximum period.

2.8.1 JUVENILE FOSTER CARE

“The time an animal is in juvenile foster care must not exceed three months.”

We do not support arbitrary time limits for animal care.

2.10 Rehoming

“Aggressive, anti-social or animals with known vices such as excessive barking or habitual escapees must not be made available for sale.”

A dogs barking cannot reliably be assessed in a shelter. Any dog will roam if not properly contained.

“New owners must be supplied with a microchip, desexing and vaccination certificate”

Owners should be presented with evidence the animal has immunity. This may be in the form of results from a titre test instead of a re-vaccination.

3.2.3 Size of animal housing areas, isolation areas and holding facilities

a. Dogs

In each instance the increased floor area for each additional dog is 0.1 square meters greater than the next size pen. Sizes should be streamlined so that two dogs can be placed in a pen one size up.

The current code requires dogs over 70 cm at shoulders to be given the largest pens. Reducing this to 60cm would mean more space is required for dogs such as:

• German Shepherd (60-65cm)
• Golden Retriever (56-61 cms)
• Rhodesian Ridgeback (63- 69cms)
• Weimaraner (59-70 cms)

There would be significant capital expenditure in building new pens and less dogs could be housed in a given space. A shelter with less pens fills up sooner. Is there evidence that the existing minimum pen sizes have resulted in animals suffering over the past 12 years? Is there animal welfare science to justify this change?

b. Cats

The minimum width for transitional period housing is new (even though minimum floor area remains the same). Existing housing should be grandfathered. Is there animal welfare science to justify the new minimum side?

4 Records

In the event that the animal is euthanased, the method used should be recorded.

—

• fails to reflect community expectations around the treatment of cats and dogs
• doesn’t address the need to reduce kill rates in our pounds and shelters
• contains provisions that make saving animals more costly and difficult
• will not result in intractable under performers reducing their kill rates
• will be used to justify the performance of high kill operators

Sections of the code have been highlighted in red and comments are boxed.

Code of Practice for the Management of Dogs and Cats in Shelters and Pounds (Revision 1)

Introduction

This Code of Practice is made under the provisions of Section 59 of Division 4 of the Domestic Animals Act 1994.

The purpose of the Code of Practice is to specify the minimum standards of accommodation, management and care that are appropriate to the physical and behavioural needs of dogs and cats housed in establishments operating as an animal shelter or Council pound.

The Code of Practice is designed to cover all animal shelters and Council pounds, and includes any holding facilities used by these establishments. Holding facilities for the short term housing of animals prior to transportation to an establishment must comply with this Code of Practice. Specific conditions apply to the long term housing of animals seized and held for periods greater than six weeks.

The Code of Practice is to be observed by the proprietor, operations manager and all other staff of an establishment. All establishments must comply with State and Local Government legislation and permits.

This Code of Practice does not apply to wildlife shelters operated by persons holding an authorised license under theWildlife Act 1975 to establish a shelter for the rehabilitation of native wildlife.

All establishments must carry a minimum of $10,000,000 Public Liability insurance cover.

Definitions

These definitions are provided solely for the purpose of interpreting this Code of Practice.

Act: the Domestic Animals Act 1994.
Animal: dog, puppy, cat or kitten.
Authorised officer: a person appointed as an authorised office under section 71, 71A, 72 or 72A of the Act.
Animal housing area: all pens, cages or modules used to house animals at the establishment.
Bed: an impervious structure, raised off the level of the floor that is large enough to cater for the size of the animal housed in the pen, cage or module.
Behavioural rehabilitation foster care: care for an animal outside of the establishment to rectify a behavioural problem to prepare the animal for return to the establishment for rehoming.
Cage: a structure designed to house a cat or kitten.
Cat: any animal identified as Felis catus.
Colony pen: a walk in structure designed to house up to eight cats or kittens.
Council: a municipal council that may be constituted as a City Council; or Rural City
Council or Shire Council.
Disinfectant: a product used on an inanimate surface to kill micro-organisms, thus sterilising the surface.
Dog: any animal identified as Canis lupus familiaris.
Establishment: an animal welfare shelter or Council pound.
Exercise area: an area separate to the animal housing area, which an establishment may use for additional exercise of animals.
Foster carer: a person who undertakes juvenile, behavioural or veterinary rehabilitation foster care for an animal outside of the establishment until the animal is fit for sale and returned to the establishment for rehoming.
Holding facilities: pens, cages or modules for housing animals for a period less than 24 hours.
Impervious: materials or sealed materials that prevent water, urine or any other liquids penetrating the material or being absorbed and held by the material.
Isolation housing: pens, cages or modules that are kept in a separate area and used for animals suspected of having, or diagnosed with, an infectious disease.
Juvenile: a puppy or kitten.
Juvenile foster care: care for a juvenile animal outside of the establishment until the animal is strong enough to return to the establishment for rehoming.
Kitten: a cat aged less than 12 weeks.
Operations manager: a person responsible for the day to day operation of an establishment.
Module: a structure designed to house a cat or kitten after the quarantine period.
On call: contactable and available to attend an establishment promptly, at any time over a 24-hour period.
Pen: a structure designed to house a dog or puppy.
Pound: any premises maintained for the purpose of impounding dogs or cats.
Proprietor: the person who owns the shelter or pound. For a Council Pound, the Council is considered to be the proprietor. In the case of a Shelter with a board of management the Executive Officer is considered to be the proprietor.
Quarantine: separation from other animals until eight days after vaccination.
Puppy: a dog aged less than 16 weeks.
Rehoming: preparing the animal for and offering for sale.
Staff: includes the proprietor, operations manager, animal attendants, volunteers and foster carers.
Transitional period: the period after a cat has been impounded for eight days.
Veterinary rehabilitation foster care: care for an animal, outside of the establishment, whilst it recovers from an illness or disease, until the animal is well enough to return to the establishment for rehoming.
Washable: an impervious surface that allows for cleaning.
Weatherproof: protection from the wind, rain and extreme temperatures to safeguard the welfare of the animals housed in the establishment.

1 Staff

1.1 Proprietor

The proprietor of an establishment must have a written health management plan that has been formulated in consultation with a veterinary practitioner. The proprietor may act as the operations manager or appoint a person to that role.

Who would the proprietor be in the case of a Council run pound? The CEO?

The health management plan must include protocols for:

• assessment for admission to the pound or shelter
• vaccination programs
• parasite prevention
• response to an outbreak of disease
• approved euthanasia techniques
• management of isolation facilities
• environmental enrichment
• assessment programs for fostering animals
• temperament and health assessment for rehoming animals
• behavioural and welfare assessment of animals impounded longer than six weeks
• removal of animals deemed unfit for continued pound/shelter care.

The proprietor of an establishment is responsible for:

• the overall management and conduct of the establishment
• ensuring compliance with legislation and Codes of Practice
• the health and well-being of all animals in the establishment and in foster care
• promoting and supporting relevant formal and informal training to staff
• ensuring there is a written and signed agreement stating who will be responsible for any building or plant work, where both parties’ responsibilities are clearly defined if the proprietor is leasing the premises
• having a written agreement with sufficient veterinary practitioners to provide prompt treatment other than first-aid and, if necessary, humane euthanasia
• the protection of staff health at the establishment.

Who is responsible in the case of a Council run pound? Should this not be the operations manager?

1.2 Operations manager

To operate an animal shelter or pound an operations manager must have experience or qualifications in the husbandry of dogs and cats to meet their physical and behavioural requirements.

It’s not made clear how this is to be measured.

Cost implication for training up new managers.

If an operations manager is in training and has not yet attained qualifications or experience then the operations manager must be under the supervision of the proprietor or a veterinary practitioner.

The operations manager is responsible for the day to day operation of the establishment which includes:

• the health and well-being of all animals in the establishment
• reporting to the proprietor on matters of compliance and reporting disease outbreaks
• carrying out the directions of the veterinary practitioner in the event of an outbreak of disease
• the supervision of staff and the provision of training
• the maintenance and collation of records and statistics
• supervision of daily feeding, watering and inspection of all animals
• supervision and examination of animals upon entry
• the overall level of hygiene in the establishment, including the disposal of waste materials
• provision of prompt veterinary attention for animals when required
• developing and prominently displaying at the establishment a plan to respond to emergency situations for both humans and animals
• monitoring physical and psychological health of animals
• seeking veterinary advice for behaviour change in an animal
• removal of animals deemed not fit for a pound or shelter environment.

1.3 Animal attendants

Animal attendants who work at the establishment must be trained and experienced to properly manage the type of animals kept at the establishment. The minimum equivalent of one full-time animal attendant must be employed for every 40 animals housed at the establishment.

What is the justification for this 20% increase in staffing requirements for animal attendants?

Will an establishment with 60 animals be permitted to employ one full time attendant and one part time attendant?

Animal attendants are responsible for carrying out the following duties and must report to the operations manager on these duties:

• daily feeding, watering and inspection of all animals
• daily cleaning of animal housing areas, i.e. hose out, replace bedding, litter trays, feeding and watering utensils
• administering medication and treatment as prescribed by veterinary practitioner
• routine disinfection of animal housing areas and equipment
• exercising of animals as required
• provision of environmental enrichment for the animals.

The animal attendant must promptly report to the operations manager animals showing any of the following symptoms:

• any serious physical or behavioural abnormality
• any change in behaviour in an animal
• apparent pain
• bleeding or swelling of body parts
• bloating of abdomen
• coughing
• diarrhoea, especially if bloodstained
• difficulty or inability to urinate or defecate
• fits or staggering
• inability to stand or walk
• lack of appetite
• lameness
• red or brown coloured urine
• repeated sneezing
• runny nose
• runny or inflamed eyes
• vomiting
• weight loss.

1.4 Veterinary practitioner

The written agreement between the proprietor and the veterinary practitioner must include arrangements for:

• the use of the veterinary practitioner’s facilities for the treatment of animals
• the provision of isolation housing if the establishment does not have a separate first aid and treatment area, or isolation housing and the supervision of animals in isolation at the establishment.

Only animals housed for veterinary treatment or isolation at a veterinary clinic and under direct veterinary supervision can be housed in pens, cages or modules contrary to this Code of Practice.

Where directed by a veterinary practitioner, unweaned, injured and diseased animals must be euthanased humanely.

1.5 Vehicle driver

Any driver of an establishment, or council, animal transport vehicle must be experienced or adequately trained to carry out the following tasks:

• assessment and care of animals being transported in accord with section 2.2 of this code
• ensuring the hygiene and cleanliness of the vehicle including routine cleaning and disinfection
• when an animal shows signs of infectious disease or defecates, vomits or urinates in the cargo area, drivers must clean and disinfect the cargo area of the vehicle before another animal is placed in the cargo area.

Animals must be transported for the minimum time practicable, taking into consideration the most direct route from the area where the animal was collected back to the holding facility or establishment.

Where the pick-up of stray or injured animals is conducted on a shuttle basis to the establishment or veterinary care, the timetable must ensure the minimum time in transit for distressed or injured animals.

Severely injured or diseased animals must be examined and euthanased, where appropriate, by an authorised officer or veterinary practitioner as soon as possible.

1.6 Foster carer

This section applies to foster care programs conducted as part of a Council pound or animal shelter operation. A foster carer who undertakes foster care must have a written agreement with the establishment.

Foster carers conducting juvenile foster care for an establishment must:

• have the permits, where required by local government, to keep the number of animals at their premises
• keep the animals in accordance with the instructions of the veterinary agreement
• assess and record the weight and condition of the animal in their care on a daily basis
• notify the establishment and present the animal to a veterinary practitioner if symptoms of illness develop
• provide environmental enrichment and socialisation in accordance with the veterinary agreement
• not allow animals kept on their premises to leave the premises unless returning them to the establishment; or for veterinary practitioner treatment
• return the animals under foster care to the establishment within the specified time set by the veterinary practitioner or at the end of three months, whichever is sooner
• permit their premises to be audited for compliance with the Act and Code by an authorised officer.

Shelters generally do ‘home checks’ before permitting a person to foster. Intruding into the privacy of people’s homes add an unnecessary disincentive for people to become foster carers. Is there evidence of a need for authorised officers to “audit” the homes of foster carers?

Foster carers conducting veterinary or behavioural rehabilitation foster care for an establishment must:

• be trained or experienced to care for and meet the needs of the animals placed in their care for rehabilitation
• not have more animals requiring juvenile, veterinary or behavioural rehabilitation foster care, in their care at any one time, than they can singularly manage
• have the permits, where required by local government, to keep the number of animals at their premises
• record the condition of the animal in their care on a daily basis, and present this to the veterinary practitioner at least every seven days
• present the animal to a veterinary practitioner for a health assessment every seven days
• keep the records required by the Code and report to the operations manager on the condition of the animals as required by the Code on a weekly basis
• permit their premises to be audited for compliance with the Act and Code by an authorised officer
• return the animals under foster care to the establishment within the specified time set by the veterinary practitioner or at the end of three months, whichever is sooner.

1.7 Staff health

Potential health risks for humans exist when working with animals. Some animals may harbour disease causing organisms, which can be transmitted to humans (zoonoses). To protect staff health, a list of common zoonoses associated with animals must be prominently displayed throughout the establishment and staff must be educated in prevention of zoonoses. All personnel working with cats, especially women of childbearing age, must be made aware of the risk of contracting toxoplasmosis.

Staff health must be protected by the provision of:

• personal protective clothing
• hot and cold hand washing facilities with disinfectant soap at the establishment
• adequate information and training on health, hygiene and safety at the induction session
• tetanus immunisation.

Members of the public’s health must be protected by providing access to hot and cold water hand washing facilities with disinfectant soap.

2 Handling, treatment and CARE of animals

2.1 Handling

Staff handling animals must be able to demonstrate the knowledge, skills, attitude and behaviour to undertake the appropriate handling techniques for the animals impounded at the establishment. Handling methods must be as humane as possible with minimum risk to the animals, staff and members of the public. The behaviour of the species and individual animal concerned must be taken into account when deciding on the methods used to handle the animal.

2.2 Admission

Every animal admitted to the establishment must be examined by a veterinary practitioner or by an experienced person, who is responsible for classifying the animals into the health status (table 1) for appropriate action:

Table 1 Health status and appropriate action to be taken upon admission

Insufficient safeguards against failed microchip scans, ‘diseased’ is too vague, many pet cats could be described as ‘uncontrollable’ if trapped and delivered to a pound.

2.3 Vaccination

All dogs sold from an establishment must be vaccinated to cover the following diseases:

• Canine Distemper
• Infectious Canine Hepatitis
• Canine Parvovirus

Should make clear that animals for which a record of vaccination exists or for which titre testing indicates immunity should not be required to be re vaccinated.

The AVA’s policy refers to the World Small Animal Veterinary Association’s (WSAVA’s) Guidelines for the Vaccination of Dogs and Cats, which state that

“Vaccines should not be given needlessly.  Core vaccines should not be given any more frequently than every three years after the 12-month booster injection following the puppy/kitten series”

The APVMA advises that antibody titre testing is available to determine if an animal needs re-vaccination.

• Canine Cough (Parainfluenza (Type II) and Bordetella bronchiseptica).

The AVA and APVMA recommend that “Non-core vaccines are required by only those animals that are at risk from those specific diseases, due to their geographic location, local environment or lifestyle.”

At what point in the dogs stay must this be administered? Is the purpose to protect the dog while in the facility?

All cats sold from an establishment must be vaccinated to cover the following diseases:

• Infectious Feline Enteritis
• Feline Respiratory Disease (feline calicivirus and feline herpes virus)

2.4 Quarantine

All animals must be vaccinated and serve an eight day quarantine period prior to animals being made available for rehoming. The only exception is if the animal was previously vaccinated and presented with a current vaccination certificate and is free from infectious disease.

At the end of the quarantine period, all animals must again be examined by the operations manager or a veterinary practitioner to assess their suitability for sale.

2.5 Isolation

All establishments must provide an area for isolation for animals suspected of having an infectious disease or must have a written agreement with a veterinary practitioner to provide isolation facilities off site.

Isolation housing within the establishment must be physically separated by an impervious barrier or a distance of at least ten metres from other animal accommodation at the establishment. Animals must be maintained in an area approved in the animal health management plan – with particular reference to the area’s airflow, workflow and cage or pen design.

All animals confined in isolation housing must be under the supervision of a veterinary practitioner and the fate of an animal must be decided by a veterinary practitioner.

Vet’s provide advice. It’s up to the establishment to decide who has the final say on the fate of an animal, especially establishments without an in house vet.

2.6 Euthanasia or removal of an animal from the establishment

At the conclusion of the statutory period specified in the Domestic Animals Act 1994 for seized or surrendered animals, animals must be:

• rehomed to a new owner, or
• euthanased because of disease, injury, behaviour, age, unsuitability for sale, or
• placed in appropriate foster care and returned at an appropriate date for rehoming, or
• released under a written agreement to a person or body which operates in accordance with the Act to care for and dispose of the animal, at the discretion of the operations manager or veterinary practitioner.

The accepted method of humane euthanasia is barbiturate overdose, which must be carried out by a veterinary practitioner.

Euthanasia must be performed in an area that is separated from animal accommodation at the establishment and must not be carried out in view of any other animals or members of the public.

If a proprietor decides that a gunshot is the only practical method of euthanasia, shooting must only be performed by an experienced operator trained in the use of firearms and only in locations where firearm use is permitted. Staff, public and nearby animal safety must be considered. This procedure must be performed away from the public and other animals.

Euthanasia methods must be carried out humanely.

2.7 Care

2.7.1 NUTRITION

Food must contain nutritive values in sufficient quantity to meet appropriate daily requirements for the condition and size of the animal.

Dogs and cats must be fed at least once a day.

Puppies and kittens between four and six months of age must be fed a minimum of twice daily

Puppies and kittens up to four months of age must receive a minimum of three feeds a day.

Food must be stored in sealed containers which must be vermin proof. The preparation of food must be conducted in hygienic areas which must be cleaned and disinfected after food is prepared. The establishment must hold a minimum of five days food, the equivalent of that required under full capacity for the establishment.

All animals must have access to a sufficient supply of fresh, clean water daily. The amount of water needed daily is approximately 50 millilitres of water per one kilogram of body weight but the amount may vary depending on a number of factors including health status, environmental temperature, amount of exercise, lactating animal, water content of diet, age etc.

Food and water containers must be non-spillable and designed to be cleaned and disinfected. Containers must not cause injury to the animals.

For dogs and weaned puppies, one food and water container must be provided for each animal. For cats, there must be one feeding bowl per adult and one feeding bowl per three kittens.

2.7.2 DISINFECTION AND HYGIENE

Maintenance of hygiene in an establishment will prevent build-up of disease causing organisms including viruses and parasitic worm eggs. An establishment must be clean and hygienic at all times.

All pens, cages and modules used to house animals must be cleaned out at least once per day (or more often as required) by hosing or other appropriate means. Animal housing areas must not be allowed to remain wet if the animal is returned to the area. All faeces, used bedding, used cat litter and uneaten food must be removed prior to cleaning. Used litter and uneaten food must be placed in a waste disposal device. Waste disposal must be in accordance with the requirements of the appropriate statutory authority. Use of a trade waste service for collection and disposal of wastes is preferable. Wastes must not be incinerated unless the incinerator is registered with the appropriate authority.

Establishments must have an adequate water supply and must be sewered, on a septic system, or have some other adequate method of disposing of faeces.

All watering and feeding utensils must be cleaned daily using chemicals in accordance with the manufacturer’s instructions. Utensils must be rinsed after disinfection to avoid poisoning.

Cats must be provided with clean litter daily. The trays, that hold the litter, must be cleaned and disinfected weekly or more often if required. Litter trays must be cleaned and disinfected between uses for different cats. Sufficient quantities of suitable litter material, such as commercial cat litter, sawdust or shredded paper, must be provided for each cat or kitten.

Disinfection of pens, cages, and modules must be done whenever the pen/cage is vacated or every eighth day with a hospital grade disinfectant, products containing Phenol must not be used. Manufacturer’s instructions for the use of these agents must be followed.

Pests including fleas, ticks, flies, mosquitoes and rodents must be effectively controlled at the establishment. Registered chemicals used for pest control must be used in accordance with the manufacturer’s instructions and must be either prescribed by a registered veterinary practitioner or used in accordance with the appropriate authority. Material Safety Data Sheets for all chemicals used at the establishment must be current and kept on site in an accessible format.

2.7.3 INSPECTION

All animals, housed at the establishment must be assessed, by staff, at least once each day for change in health or temperament, and for the purpose of reporting each animal’s general appearance and behaviour. Puppies and kittens must be observed at least twice each day.

It is the responsibility of animal attendants at establishments to report any animal that appears sick, injured or whose behaviour has changed, to the operations manager or proprietor or veterinary practitioner as soon as possible. Animals suspected of having an infectious disease must be housed in isolation.

2.7.4 Enrichment

Environmental enrichment should be provided regularly to all animals- this could be in the form of exercise, foraging opportunities, toys, play materials, grooming and socialisation – including with humans and the animal’s own species. All enrichment and socialisation must be controlled to avoid risk of contamination of other animals. Items must be able to be disinfected between uses by animals or be disposable.

The proprietor or operations manager is responsible for ensuring that where an animal enters the establishment and is likely to be housed for an extended period for legal reasons, the animal must be assessed on entry for their physical, psychological and social well being by a veterinary practitioner and then at least once a month by a veterinary practitioner during the stay of the animal.

Animals housed long term must have environmental enrichment daily; this must be assessed for safety to the handler and the animal and should be regularly varied.

The type of enrichment could vary depending on the animal, the type of containment required for the animal and the period of confinement, as suggested in Tables 2 and 3.

2.7.5 Exercise/socialisation areas for dogs

Exercise areas must be securely fenced to prevent the escape of the animal and a person must directly supervise animals when more than one animal is placed in the area, to ensure the animals are not in danger of attack or other injury.

Exercise and socialisation areas must be designed to prevent escape, for security and safety of animals and humans.

The type of exercise and socialisation could vary depending on the animal, the type of containment required for the animal and the period of confinement, as suggested in Tables 2 and 3.

Table 2. Enrichment, exercise and socialisation of dogs and puppies

2.7.6 EXERCISE/SOCIALISATION AREAS FOR CATS

Exercise areas must be completely enclosed to prevent the escape of the animal and a person must directly supervise animals when more than one animal is placed in the area to ensure the animals are not in danger of attack or other injury.

Exercise and socialisation areas must be designed to prevent escape, for security and safety of animals and humans.

The type of exercise and socialisation could vary depending on the animal, the type of containment required for the animal and the period of confinement, as suggested in Tables 2 and 3.

Table 3. Enrichment, exercise and socialisation of cats and kittens

After assessment, for compatibility in exercise and socialisation, up to eight socially compatible cats can be exercised together provided they are the same sex or desexed.

Exercise areas must:

• contain litter trays for each cat
• be the minimum equivalent size of a colony pen
• be well maintained
• offer a form of enrichment (such as scratch posts, toys, access to high and low areas for hiding or rest).
• have a secure roof and be escape proof
• have some shade within/over the area
• take into consideration the health and hygiene of both animals and humans
• allow access to water.

2.8 Foster care

This section provides minimum standards for the operation of foster care conducted by establishments. The only time an animal can be placed in foster care is on the grounds of juvenile, veterinary rehabilitation or behavioural rehabilitation foster care. The animals placed in foster care must be permanently identified by microchip and they remain the property of the establishment. Animals in foster care must be returned to the establishment for rehoming as foster care must not be considered as the animal being ‘permanently removed’ from the establishment. An animal in foster care must not be sold or rehoused from the foster care premises – the animal must be returned to the establishment for the rehoming process.

If for any reason an animal has a litter whilst in foster care the animal and all of the young must be returned to the establishment for the rehoming process.

The establishment’s veterinary health management plan must identify the requirements for foster care for animals if foster care is to be completed by that establishment.

Staff conducting foster care for an establishment must:

• be trained and experienced to care for and meet the needs of the animals placed in their care
• have the permits, where required by local government, to keep the animals at their premises
• have a signed agreement with the establishment
• keep the records required by the Code and report to the operations manager on the condition of the animals as required by the Code
• meet the requirements of the Act.

Foster care must only be undertaken with the signed approval of a veterinary practitioner. The veterinary practitioner must ensure that the animal is suitable for foster care and sign the animal’s records endorsing such approval.

A health plan determined by a veterinary practitioner must be provided for each animal being placed in foster care. The health plan must provide instructions on the appropriate care, nutrition, hygiene, exercise and husbandry of the animals to be placed in foster care. Consideration must be given to any other animals in the carer’s home.

Where, in the veterinary practitioner’s opinion, the animal’s progress is such that they believe the animal may not sufficiently improve in the maximum period allowable to enable the animal to be rehoused, the animal must be returned to the establishment.

Medical and behavioural factors are independent, and a vet is not qualified to make a statement on a behavioural issue any more than a behaviourist is qualified to make a statement on a medical issue. Why make it mandatory to terminate a foster care placement simply because a veterinarian believes the animal may not be ready for rehoming by the end of a maximum period?

2.8.1 JUVENILE FOSTER CARE

The purpose of juvenile foster care is to allow a healthy kitten or puppy to be cared for off site in preparation for sale: to ensure the kitten or puppy is the health, age and weight required for vaccination and desexing prior to being sold by the establishment.

Kittens and puppies must be returned to the establishment when it is deemed appropriate by the veterinary practitioner to desex the animal post vaccination. The time an animal is in juvenile foster care must not exceed three months.

2.8.2 VETERINARY REHABILITATION FOSTER CARE

The purpose of veterinary rehabilitation foster care is to provide an opportunity for animals with a recoverable injury or non-infectious illness to be rehomed by the establishment. Animals that have infectious diseases must not be placed in veterinary rehabilitation foster care.

Animals that are placed in veterinary rehabilitation foster care must be microchipped, vaccinated and wormed prior to leaving the establishment and they must have completed the eight day quarantine vaccination period. A veterinary practitioner must provide in the health plan an expected date of return to the establishment for rehoming and must assess the progress of the animal for medical improvement.

Animals in veterinary rehabilitation foster care may be exercised and have behavioural enrichment provided off the foster carer’s premises during the period of rehabilitation with the approval of the authorising veterinary practitioner.

Animals placed in veterinary rehabilitation foster care must be returned to establishment for the purposes of desexing and rehoming. The maximum period allowed for an animal to be in medical rehabilitation foster care is three months.

2.8.3 BEHAVIOURAL REHABILITATION FOSTER CARE

The purpose of behavioural rehabilitation foster care is to provide an opportunity for animals be retrained to rectify a behavioural trait restricting the animal being rehomed by the establishment. Animals that have medical issues or infectious diseases must not be placed in behavioural rehabilitation foster care. Animals that fail temperament tests must only be placed in behavioural rehabilitation foster care under recommendation from an animal behavioural specialist.

Animals that are placed in behavioural rehabilitation foster care must be microchipped, vaccinated and wormed prior to leaving the establishment and they must have completed the eight day quarantine vaccination period. An animal behavioural specialist must provide a training plan and expected date for return to the establishment for rehoming and must assess the progress of the animal for behavioural improvement.

Animals placed in behavioural rehabilitation foster care may only be exercised off the foster carer’s premises with the approval of the animal behavioural specialist. During the period of behavioural rehabilitation foster care, the authorising animal behavioural specialist must assess the progress of the animal to ensure that it is making acceptable improvement.

Animals placed in behavioural rehabilitation foster care must be returned to establishment for the purposes of desexing and rehoming. The maximum period allowable for an animal to be in behavioural rehabilitation foster care is three months.

2.9 Responsible pet ownership

Establishments which rehome animals must assist in promoting responsible pet ownership in the community by the following methods:

• providing prospective buyers with advice on the most suitable type of pet for their environment (consider yard size, exercise requirements, children etc.). Prospective owners should be encouraged to seek advice on numbers of pets allowed or legal requirements from their local council and to gain approval from landlords in the case of rental premises, prior to acquiring an animal.
• providing new pet owners with advice on pet care and information leaflets about the veterinary attention required for animals after purchase (such as follow-up vaccination), and current legislation covering the registration of animals.

2.10 Rehoming

All animals rehomed from an establishment must be microchipped, wormed, desexed and vaccinated.

Aggressive, anti-social or animals with known vices such as excessive barking or habitual escapees must not be made available for sale.

Animals with a defect that does not significantly affect the quality of life of the animal can be made available for sale. This decision must be made by a veterinary practitioner and brought to the attention of the prospective owner prior to sale or giving away.

New owners must be supplied with a microchip, desexing and vaccination certificate. New owners must be given literature about Council registration, feeding, housing, training and responsible pet ownership and to seek advice about problems with the pets from veterinary practitioners or people with experience in animal care and management.

Establishments must develop and practice standard procedures for assessment of health, temperament and sociability in animals selected for rehoming.

2.11 Guarantee

If an animal is not acceptable to a purchaser because of health, physical or other reasons, excluding accidents, which are supported by a statement from a veterinary practitioner, within seven days of purchase, proprietors must accept the animal back and refund the purchase price of the animal.

If an animal is returned within three days for any other reason, the proprietor must refund 75% of the purchase price or offer a replacement animal with the same guarantee.

If the animal dies or is euthanased as a result of a disease that is traceable to the point of sale, the proprietor must refund the purchase price or offer a replacement animal with the same guarantee.

2.12 Returning (long term) seized animals to owners

Owners must be advised that the animal has been managed according to legislative requirements and of any behavioural issues or problems that have been noted. They must be strongly encouraged to seek advice from an animal behavioural specialist or training expert on rehabilitating the animal back into the home environment.

2.13 Public access to establishments

Reasonable periods for public access to the establishment must be provided during working hours. Public access after hours or on weekends at an establishment may be made by appointment with the authorised officer or an animal attendant at the establishment.

2.14 Release of animals to research or teaching institutions

Pound animals may only be released to research organisations with a Scientific Procedures Premises Licence (SPPL) or Scientific Procedures Field Licence (SPFL), under the provisions of the Code of Practice for the use of animals from municipal pounds in scientific procedures.

2.15 Use of animals for research or teaching within a pound or shelter

Any studies must be carried out in accordance with Animal Ethics Committee Approval under a Scientific Procedures Premises Licence (SPPL) or Scientific Procedures Field Licence (SPFL) issued under the Prevention of Cruelty to Animals Act 1996.

3 transport vehicles and Animal housing

3.1 Council, contracted to council and establishment animal transport vehicles

Council and establishment vehicles used for the transport of animals must have the following features:

• provision for animals to be physically separated and restrained or individually enclosed by compartment or cage
• if dogs and cats are transported in the same vehicle the separation between the dog and cat must be solid and opaque
• any cages in the cargo area are to be secured to the vehicle to prevent movement of the cage
• no protrusions or sharp edges in the framework, doors, partitions, etc
• any additional equipment stored in the animal cargo area must be secured or separated to prevent movement or injury to an animal being carried
• a design that is both escape-proof and prevents the protrusion of head and/or limbs of any animal carried
• floors must be strong enough to bear the weight of the animals being transported, and must have a non-slip surface to minimise the likelihood of injury
• weatherproof with adequate ventilation of vehicles both when stationary and in motion
• facilities for ease of loading and unloading animals with minimal risk of injury to the animals and humans
• materials and a design that allows for effective cleaning and disinfection of the cargo area.

3.2 Animal housing

Temperature, humidity and ventilation must be considered at the establishment.

The animal housing areas must have:

• natural lighting or lighting that duplicates the characteristics of natural light including a simulated day/night period
• adequate fire extinguishers or other fire protection in each of the animal housing facilities
• sufficient ventilation to keep animal housing areas free of dampness, noxious odours and draughts
• supply of fresh air.

Where animals are housed in a totally enclosed area, where forced ventilation is the only form of air movement, the following is required:

• an air change rate of a minimum of eight changes per hour and sustained to prevent the build up of foul odours
• ventilation must not cause draughts and must distribute fresh air evenly to all of the animal housing areas
• temperature must be maintained in the range of 15-27 °C
• air recirculation units incorporating effective air cleaning and filtration to ensure the removal of infectious organisms and chemicals
• a back-up and alarm system in case of power failures or breakdown of ventilation and temperature control mechanisms.

3.2.1 Design of animal housing areas, isolation housing and holding facilities

Animal housing areas, isolation housing and holding facilities separating dogs and cats must be physically separated by an opaque and impervious barrier. Areas must be constructed of impervious, washable materials designed to facilitate cleaning and disinfection.

The floors of animal housing areas and holding facilities must be constructed of an impervious material that is free of cracks and sealed to assist with drainage and disinfection. Animal housing areas and holding facilities must be constructed not to allow water, wastes or urine to pass between individual pens, cages or modules.

Animal housing areas and holding facilities must be completely enclosed with a solid or wire roof to prevent the escape of animals. Animal housing areas and holding facilities must not have gaps in the design that would allow an animal to protrude its head outside the housing area.

Outdoor animal housing areas and holding facilities must be encircled by a 1.8 metre high fence with lockable gates to prevent the escape of animals. Outdoor animal housing areas and holding facilities must have weatherproof sleeping quarters and a bed to provide protection from extremes of weather.

Preferably, animal housing areas should not be built to face each other as this will increase the noise and spread of diseases between animals.

Cat cages and modules must have an impervious barrier between them. Where cat housing areas face each other, the distance between the cat housing areas must not be less than 1.2 metres.

Where dog housing areas face each other and the drainage line is centrally located between the pens, an impervious partition one metre high must be centrally installed in the area to reduce the possibility of the spread of disease into the opposite housing area during cleaning. Individual drainage outlets must be incorporated in each pen and connected to a completely enclosed drain or pipe. Drains at the front of dog pens must be enclosed to prevent the animal or person walking through waste water. Floors of dog pens must be graded to this drainage outlet. An impervious barrier one metre high and sealed to the floor must separate all dog pens and dog exercise areas.

3.2.2 Examination, treatment and euthanasia areas

If the establishment does not have a written agreement with a veterinary practitioner for the use of their facilities then a separate first aid treatment area must be provided with a table which can be readily cleaned and disinfected, lighting and shelving, and first-aid materials including dressings, disinfectants and medicines to treat open wounds. Restricted drugs kept on the premises must be stored and used in accordance with the appropriate legislation. Hot and cold running water must be available in the examination area of the establishment.

3.2.3 Size of animal housing areas, isolation areas and holding facilities

a. Dogs
During the statutory and quarantine period, adult dogs must be housed only one dog to a pen. Up to four weaned puppies can be housed in a pen together if they are from the same litter or, if from different litters, at the conclusion of the quarantine period following vaccination.

Post quarantine, compatible dogs that are assessed suitable for rehoming, may be housed two to a pen.

Dogs surrendered together may be housed together providing the owner states that they are compatible and were normally housed together.

Where dogs are housed together they must have separate beds and food containers.

One third of the area of each pen must be weatherproof and include a bed.

Table 4. Minimum pen sizes for dogs or up to four puppies

In each instance the increased floor area for each additional dog is 0.1 square meters greater than the next size pen. Sizes should be streamlined so that two dogs can be placed in a pen one size up.

The current code requires dogs over 70 cm at shoulders to be given the largest pens. Reducing this to 60cm would mean more space is required for dogs such as:

• German Shepherd (60-65cm)
• Golden Retriever (56-61 cms)
• Rhodesian Ridgeback (63- 69cms)
• Weimaraner (59-70 cms)

There would be significant capital expenditure in building new pens and less dogs could be housed in a given space. A shelter with less pens fills up sooner. Is there evidence that the existing minimum pen sizes have resulted in animals suffering over the past 12 years? Is there animal welfare science to justify this change?

b. Cats
Cats must be housed individually in cages or modules constructed of impervious, washable materials during the statutory and quarantine period. Cats surrendered together may be housed together providing the owner states that they are compatible and were normally housed together.

Statutory eight day period cages or transitional period cages can accommodate up to three kittens providing that the kittens are from the same litter or, if from different litters, at the conclusion of the quarantine period following vaccination. Up to six kittens can be held together in module cages providing that their temperament has been assessed as suitable for colony housing.

Cats must not be kept in statutory eight day period cages for more than eight days. Cats kept for longer than eight days must be housed in transitional period cages, modules or colony pens.

Male cats kept in colony pens must be desexed and all cats must have completed their vaccination period.

Colony pens must contain for each cat housed in the colony pen an individual litter tray and food container and a bed for each cat/kitten that provides a visual barrier from the shared area.

Table 5. Minimum cage, module and colony pen sizes for cats or up to three kittens

**A module or colony pen must contain at least two levels, excluding the floor, and these levels must be connected to the floor by means of a ramp or pole.

The minimum width for transitional period housing is new (even though minimum floor area remains the same). Existing housing should be grandfathered. Is there animal welfare science to justify the new minimum side?

4 Records

The proprietor must record the following details and retain these records for a period of not less than five years:

(a) For animals handed in by their owners or owner’s agent:

• species of animal
• name of the animal
• name of the owner of the animal
• contact telephone number and address of the owner or owner’s agent
• a description of the animal including:
• • sex and whether the animal is desexed
  • breed type
  • colour
  • age
  • details of medical, dietary, bathing and grooming requirements
  • vaccination status
  • heartworm treatment (dogs)
  • any behaviour problems
  • any permanent identification
• reason the animal was handed in.

(b) For animals seized under the Domestic Animals Act 1994:

• species of animal
• location where animal was seized
• time and date animal was seized
• name and address of person who seized the animal (business address of authorised officers or Council contractors)
• reason why animal was seized
• a description of the animal including:
• • sex and whether the animal is desexed
  • breed type
  • colour
  • age
  • any injuries noted when seized
  • any behaviour problems noted when seized, e.g. aggression
  • any permanent identification.

(c) For animals in foster care:

• species of animal
• address where animal is in foster care
• date animal was taken to foster care
• date animal was returned to establishment
• name, address and telephone number of foster carer
• reason why animal is in foster care
• a description of the animal including:
• • sex and whether the animal is desexed
  • breed type
  • colour
  • age
  • details of medical, dietary, bathing and grooming requirements
  • vaccination status
  • heartworm treatment (dogs)
  • any behaviour problems
  • permanent identification.

(d) Fate of animal - including recovery by owner, rehoming or euthanasia

• In the event that the animal is recovered by an owner:
• • name and address of person who recovered the animal
  • registration status of the animal at time of recovery
  • Council registration and microchip number of the animal
  • municipal area in which the animal is to be kept.

• In the event that the animal is rehomed:
• • microchip number and date of implantation
  • date Domestic Animal Registry was notified
  • date Council notified that new owner lives in that Council area
  • date animal was wormed
  • date animal was desexed
  • date animal was vaccinated and by whom it was vaccinated.

• In the event that the animal is euthanased:
• • date and reason the animal was euthanased.

Should also record method used.

• In the event that the animal is sent to a research or teaching organisation or used in research at the establishment:
• • permanent identification number of the animal
  • date animal was sent to research or teaching organisation
  • name of the research or teaching organisation
  • SPPL or SPFL number of the research or teaching organisation
  • the Animal Ethics Committee number relevant to the animal’s requirements.

A. Being killed despite available alternatives.


While Victorian’s would be horrified to know of the high kill rates in our pounds and shelters, the body overseeing the Code of Practice they operate under doesn’t appear that concerned.

In the first revision to the Code since 1998, the Bureau of Animal Welfare has introduced new restrictions that would make the work of organisations trying to rehome animals harder.

Fireworks and thunderstorms often result in an influx of frightened runaway dogs being impounded. Instead of killing healthy dogs to make space for them, some organisations use foster carers. The proposed code bans the use of foster care for this and any other grounds not listed in the Code.

2.8 Foster Care
The only time an animal can be placed in foster care is on the grounds of juvenile, veterinary rehabilitation or behavioural rehabilitation foster care.
Proposed Code of Practice for the Management of Dogs and Cats in Shelters and Pounds

The authors of this draft don’t seem overly concerned about whether cats and dogs get out alive, as long as they’re comfy while impounded. This is completely at odds with community expectations but appears to be consistent with the definition of animal welfare the Bureau chooses to put on its homepage:

Animal Welfare
Good animal welfare requires disease prevention and veterinary treatment, appropriate shelter, management, nutrition, humane handling and humane slaughter/killing.
Victorian Bureau of Animal Welfare

This draft of the Code unfairly limits our alternatives to killing and does precious little to increase reclaim or rehome rates. It simply doesn’t reflect community attitudes towards companion animals.