BVZS Response to Welsh Circus Consultation

BVZS response to Welsh circus consultation

BVZS response to Welsh consultation on the use of wild animals in circuses, December 2015

Introduction:

The British Veterinary Zoological Society (BVZS)is thespecialistdivision of theBritishVeterinary Association (BVA) recognised as having responsibility for the care and welfare of exotic pets, zoo animals and wildlife. It has a current membership of around 400, with many members involved directly in the veterinary care of wild and captive wild animal species, or research into the welfare of these species. Our membership also includes current inspectors for the circus licensing system in England. We welcome the opportunity to comment on the early stages of the Welsh consultation.

The BVZS position on the use of wild animals in circuses is broadly encompassed by the following principles, which have been the basis of recent responses to consultations in Scotland and England. We would recommend that the Welsh team study those consultations, and their outputs, as they proceed with their own consultation.

BVZS agrees in principle that the days of travelling wild animal circuses solely for entertainment purposes should beover. However, it does not follow that we consider that an immediate ban is necessarily the best method by which to arrive at this longer term aim.

The main issues of concern which we feel need to be addressed in any consultation are:

1.The exact definitions of “circus” and “wild animal”. It is not acceptable in either case to assume that there is a commonly understood definition of these terms.

2.The potential impact on other travelling animal displays, educational exhibits and performance animals used for television, films etc.

3.The development of realistic plans for the transitional care and demobilisation of existing circus animals prior to abolition.

Comments:

We have a number of concerns about the Welsh study as laid out below:

1. Context.
2. The questionnaire states that it will be distributed globally for comment. We feel that the situation pertaining to travelling circuses in Wales warrants a focused geographically and culturally-specific response to the Welsh conditions, now and in the future. Standards of welfare, and attitudes towards animal use and abuse, vary widely across the world, and even across Europe. Consequently, we believe that a comparative approach with other countries and jurisdictions is unnecessarily complicated and not likely to yield the best set of parameters by which to judge the Welsh situation.
3. Any changes to legislation should only be based on scientific fact, and circus animal welfare in the UK has been substantially covered inthree previous reports, the most recent in 20071,2,3. We do not consider that there are likely to be substantive differences between the situation in Wales and those in the remainder of the United Kingdom. Therefore, this consultation should focus instead on specific issues relating to the welfare of animals in travelling circuses as applicable to Wales.

1. Definition.

The study is stated explicitly to look at the role of wild animals in circuses. However, neither of these terms is clearly defined.

1. Animal species. It is important to realise that the range of animal species used in circuses ranges from domesticated (e.g. horse) to non-domesticated (e.g. tiger). In addition, there are species that are considered exotic in the UK but which would be considered domesticated in other contexts (e.g. anoa, camel). Furthermore, the supporting text and emails associated with the study imply that the role of “performing” animals in general may be considered. We have reservations about this approach (see 2b below), but in this context species might range from domesticated (e.g. ferrets) through exotics commonly kept as non-traditional companion animals (e.g. reptiles), towild species that have been used in a domestic context for centuries (e.g. raptors). In order for this consultation to develop meaningful and applicable outcomes, there is a need for more clarity in the scope and definition of the species that are being considered, and in what context. In practice at present, the use of "wild" animals in circuses is defined by listing under the Dangerous Wild Animals Act 1976 (as amended). For some of the species listed above this may not not appropriate, and in addition the majority (if not all) animals used in performances generally in the UK are captive bred and reared and thus habituated to their environment; the term wild as defined by the act may not be suitable, and the animals cannot be considered “wild” in the commonly accepted sense either.In the meantime, there remains no clearly defined legal position on which animals would clearly be unacceptable (we would suggest, for example, polar bears and sea lions). Clarity of definition by the use of lists would be beneficial.
2. Circuses. Whilst the survey team may feel that there is common acceptance as to what constitutes a “travelling circus”, there is again need for much tighter definition in the consultation. There are a wide variety of contexts nowadays in which animals travel for entertainment or educational purposes, such as to visit agricultural shows, schools or even private individuals (e.g. for childrens’ parties). Other uses of animals for performance purposes would include use in film and television productions. Whilst BVZS is strongly of the opinion that such uses of animals do require regulation, and indeed that there may be grounds for further consideration of regulation in some of these areas, this is not the stated purpose of the current consultation. We do not believe that regulation specifically for travelling circuses of the kind commonly understood is likely to be relevant or beneficial in the wider context of animal use for the above purposes.

1. Methodology

BVZS has circulated the questionnaire provided to a number of our expert members (in both animal welfare in general and circus licensing in particular). There is a consensus that the methodology is problematic, both in terms of the distribution and selection of respondents, and in terms of the questions being asked. We consider there is a definite possibility of selection bias from the way in which the survey has been distributed, and the global dissemination to targeted “experts” in response to questions about a geographically and culturally-specific issue. Furthermore, the specific questions are so open and subjective that we do not believe they will generate anything other than the most general information even in aggregated form, and are unlikely to be tightly relevant to the circus situation. Within our own organisation (of specialised veterinarians) there was no clear consensus on either the best way to answer these questions or what acceptable consensus answers might be. Although individual responses may have been received by the survey from our members we are satisfied that this corporate response reflects the Society’s overall position more accurately than is allowed for in the questionnaire response format. Our recommendation would be that the survey team re-evaluate their approach, and instead ask respondents specific questions about the actual situation on the ground in Wales at the current time, encompassing for example:

1. the adequacy of the existing legislative framework including the over-arching demands of the Animal Welfare Act 2006
2. whether animal keepers are discharging their responsibilities under the above and whether there is active and effective enforcement
3. conditions in which the animals are actually kept
4. the practicalities of the functioning of a circus over the course of a performance season
5. the adequacy of current inspection systems and access to veterinary care.

Once a detailed picture has been built of the above issues, it will be possible to make more meaningful and concrete proposals as to whether further action is relevant in the Welsh context. An argument could be made that a focus on the vigorous enforcement of existing legislative powers, together with making use of the inspection lessons learned from the English experience, would be a proportionate response.

References:

1. Kiley-Worthington, M. (1989). The training of circus animals.Animal Training: a review and commentary on current practice. Universities Federation for Animal Welfare, Potters Bar, Hertfordshire, 65-81.
2. All Party Parliamentary Group for Animal Welfare (1997) A Report into the Welfare of Circus Animals Tuesday, July 01, 1997. (accessed 17/12/ 2015)
3. Radford, M. (2007) Wild Animals in Travelling Circuses (October 2007), The Report of the Chairman of the Circus Working Group.
   

Mark Stidworthy MA VetMB PhD FRCPath MRCVS

RCVS Recognised Specialist in Veterinary Pathology (Zoo and Wildlife)

President, British Veterinary Zoological Society

On behalf of BVZS Council

17th December 2015

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