Guest guest Posted February 10, 2005 Report Share Posted February 10, 2005 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.... ******************************* 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, ---------- Version: 7.0.300 / Virus Database: 265.8.6 - Release 2/7/2005 Quote Link to comment Share on other sites More sharing options...
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