Your comments must be in by 12th Feb..

[Guest guest]

The deadline for everyone to put in their 2 cents to the HK Govt. is 12th

Feb!!!! Sorry it's late but we've had a problem with it.

 

You can either cut and paste this following reply as your own if you agree with

it and send it to Dave, or you can edit it as you see fit but please do send it

to Dave if you haven't already. We need all the help you can get on this one.

Anyone can do it as long as they live in HK- be they individuals or

organizations - please also forward widely and ask friends to send it in too....

 

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8th February 2005

 

 

 

Dr David Burrows

 

david_jg_burrows

 

Agriculture, Fisheries and

 

Conservation Department

 

5/F Cheung Sha Wan Government Offices

 

303 Cheung Sha Wan Road

 

Kowloon

 

 

 

 

 

Re: ADDITIONAL CONDITIONS ATTACHED TO THE LICENCE:

 

(Under Regulation 5(3) of Public Health (Animals and Birds)

 

(Animal Traders) Regulations, Cap.139)

 

(Applicable to dog and cat traders)

 

Proposed update 2005

 

 

 

 

 

Dear Dr Burrows,

 

 

 

Thank you for your letter asking for suggestions or comments on the proposed

amendments for conditions affecting dog traders.

 

 

 

Although I fully support these efforts to improve the traders' license by the

implementation of these new conditions I cannot state strongly enough that I

feel in order to make any substantial improvements in this trade, the Govt.

should undertake to amend the laws affecting animals, their trade and welfare as

soon as possible. It is important however to have new conditions already in

place for when that happens. Improved laws with penalties realistic enough to

indeed act as a deterrent will in themselves help to fund the implementation of

these laws

 

 

 

The No Kill City Forum are hoping that this consultation exercise will result in

some consequential additions to the proposed conditions attached to the license

for dog and cat traders by the Director of the Agriculture Fisheries and

Conservation Department. Attached are some suggestions that our group has come

up with.

 

 

 

 

 

Re condition ©

 

All dogs of any age in the licensed premises must be implanted with a device

( " microchip " ) of the description set out in Schedule 3 of the Rabies

Regulations, Cap 421A: the device (microchip) must be implanted by a registered

veterinary surgeon in Hong Kong, or by an authorized officer of the Agriculture,

Fisheries and Conservation Department, and properly registered and recorded in

this department's database records with full details of the dog and place and

keeper, and all other details required by AFCD. A scanner for reading the

device must be readily available in the licensed premises at all times.

 

I would like to see a similar control / monitoring system introduced for cats at

least.

 

 

 

Re condition (d)

 

All dogs of any age in the licensed premises must have been fully vaccinated

including booster(s), against canine distemper, canine parvovirus, infectious

hepatitis and parainfluenza, using a vaccination programme to the satisfaction

of the Senior Veterinary Officer to successfully prevent these diseases. The

vaccinations must be supported by a vaccination certificate and health

certificate issued by the registered veterinary surgeon which records full

details including the number of the microchip implanted in the dog, date and

place of vaccination, the keeper, recommended date of boosters and other

relevant details. Vaccination carried out before arrival in Hong Kong (imported

dogs) must be certified by a veterinarian registered in the country of origin.

 

 

 

I would like to see a similar control / monitoring system introduced for cats at

least.

 

 

 

Re condition (e)

 

The original vaccination certificate and health certificate of each dog issued

and signed by a registered veterinary surgeon or a veterinarian registered in

the country of origin must be immediately available in the licensed premises for

inspection by an authorized officer at all times.

 

 

 

We would like to see a similar system introduced for cats.

 

 

 

We would also suggest that along with the above documentation, the current

conditions in the Code of Standards section 19 should be amended - it should

also be necessary for the trader to have documentation pertaining to the origin

of the animals for sale on the licensed premises i.e. breeders name, address,

contact numbers and location of premises where the animal was kept prior to

first sale and any subsequent locations prior to sale to the licensed premises.

 

 

 

For animals not imported, the breeders Hong Kong ID number and dams' microchip

number (currently in the case of dogs) are also important details to be recorded

 

 

 

This will enable animals to be traced back to their origin (place of birth),

helping in investigation if there are concerns as to their source & with

monitoring and enforcement of other current and future animal related

legislation (disease control (CAP 461) / commercial breeder / smuggled / illegal

trade etc) as well as provide more information and statistics on the animal

trade in HK in general.

 

 

 

We also feel section 20 in the Codes of Standards should be modified - not only

should a quarterly return be submitted to the Director for animals and birds

imported by the licensee but also a return regarding the origin and fate of all

animals entering the premises should also be required.

 

 

 

Re condition (f)

 

A notice as at Appendix A, in both English and Chinese, provided by Agriculture,

Fisheries and Conservation Department must be displayed at all times in a

prominent position at the entrance of the licensed premises.

 

We would like to see a similar noticed displayed for cats re vaccinations,

health cert and hopefully microchip

 

 

 

Re condition (g)

 

When a dog is sold or otherwise changes ownership or location, it must be

accompanied by the original vaccination and health certificates which must be

given to the new owner/keeper of the dog together with the dog. The microchip

must be checked and the details shown in the scanner to the purchaser or new

keeper, and checked in their presence against the certificates and documents.

 

We would like to see a similar control / monitoring system introduced for cats

at least.

 

 

 

Re condition (i)

 

The transaction including the microchip number must be fully recorded in the

register as required in Section 19 of the Code of Standard.

 

We fully support this move (see previous comment at (e) above), however in the

existing condition, Section 19, the described form of the register does not

currently require any microchip number to be recorded and would also need to be

modified. To make this condition effective it should also be necessary to detail

in the register other information as mentioned in the comments referring to

condition (e) and it would also be beneficial to have recorded the veterinary

practice or veterinary surgeon responsible for implanting the microchip

 

 

 

Re condition (j)

 

Not less than 50% of the floor area of each primary enclosure in which dogs or

cats are kept shall be solid or covered at all times with a solid platform or

sleeping board of a size and design suitable to enable all animals kept in the

primary enclosure to stand, sit and lie comfortably. Such solid area, platform

or board shall be constructed of a material which is substantially impervious to

moisture and may be readily sanitized.

 

We fully support this move and would like to see more specific conditions

introduced re improved husbandry and housing as appropriate for both cats and

dogs and other species sold by animal traders. For each species environmental

enrichment and social requirements should also be addressed

 

 

 

 

 

 

 

We understand that this consultation exercise specifically relates to the trade

in dogs and appreciate the opportunity to comment on the trade as there have

been many concerns about the welfare of such pups and practices with in the

trade in general. Again we stress that we are deeply concerned that there are no

laws that seem to regulate breeding (commercial or otherwise) of any domestic

pet. It has been shown in other countries that large scale animal abuse can be

found in puppy mills, puppy farms or on the premises of dealers in such animals.

 

 

 

We understand that later this year there will be a review of The Public Health

(Animals and Birds) Ordinance and Subsidiary Legislation (CAP 139) and hope that

the law will be thoroughly reviewed and experts, interest groups and the

community will again be consulted in the process. We also hope that the whole

process including enactment of the revised law will be expedited.

 

 

 

 

 

Thank you once again for this opportunity to comment.

 

 

 

Yours sincerely,

 

 

 

 

 

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