Tuesday, February 21, 2012

BC Enacts Sled Dog Care Regulations


While dog mushers throughout Canada and Alaska were preparing for the season’s most prestigious races, the British Columbia Ministry of Agriculture created regulations defining the standard of care for sled dogs and an official Code of Practice, essentially a document defining what the British Columbia Provincial government considers to be the best practices that should be adhered to by sled dog kennel owners and operators.  Quoted in the Vancouver Sun, Agriculture Minister Don McRae said the Sled Dog Code of Practices and standards of care regulation were in response to “the horrific events at Whistler” two years ago.

To a large extent, the B.C. Sled Dog Standards of Care and Sled Dog Code of Practice mirror recommendations found in the Mush with P.R.I.D.E. Guidelines.  The code and standards were developed by a Standards of Care Working Group consisting of Ministry of Agriculture staff, academics with expertise in the field of animal welfare, the BC Society for the Prevention of Cruelty to Animals, veterinarians and “sled dog industry representatives”.   The new regulations will come into effect between now and October 1, 2012. 

The Code of Practices can be downloaded from http://www.gov.bc.ca/agri/down/sled_dog_code_of_practice.pdf  and the Sled Dog Standards of Care regulation can be downloaded at http://www.gov.bc.ca/agri/down/sled_dog_standards_of_care_feb2012.pdf

Comments:

The B.C. Standards of Care makes a clear distinction between a dog’s Confinement Area and Shelter.

The Alaska State Veterinarian’s office has had a difficult time making a similar distinction in its standards of animal care development process.  The BC regulation makes that distinction very clearly be defining “containment area” as “a sled dog’s pen or the area in which a tethered dog can roam.”  The regulation does not define ‘shelter’, but it is well addressed in Part 2, Division 1 – Containment of Sled Dogs.  This section requires that each containment area includes a dog house that is large enough for sled dogs to “stand, turn around and lie down comfortably.”

The B.C. Standards of Care has specific space and construction requirements for both pens and tethers.

The new regulation requires that pens used to confine a single sled dogs be a minimum of  9.3  m2 and that one housing 2 dogs be at least 13.0 m2.  This equates to 100 square feet for a single dog, and just shy of 140 square feet for two dogs.  If more than two are housed in a pen, the regulation also requires “sufficient space for each sled dog to engage in species-typical behaviors and maintain adequate social distance from other dogs.” 

The B.C. regulation restricts tethering methods to those in which a post is used to elevate the chain above ground level, and requires the chain be at least 1.83 m (6 feet) in length.  This is very consistent with Mush with P.R.I.D.E. guidelines, and provides each dog approximately 10.5 m2 (113 sq. ft.) of space.  Unlike the PRIDE Guidelines, the BC regulation does not permit a system that allows the chain to rest entirely on the surface of the confinement area. 

The B.C. Standards of Care require dogs to be maintained at a healthy weight, based on a widely available body condition scale.

Sled dogs that score less than “3” or more than “7” on the widely available Nestle’ Purina Body Condition System, which has been recommended for inclusion in Alaska’s standard of care.  This system is very similar to the Henneke Body Scoring System that is widely accepted for the evaluation of horses.  On this Purina BCS 9 point scale, any dog scoring less than a 3 is consider too thin to maintain good health, and any scoring higher than 7 is considered too obese to be healthy. 


Concerns:
The B.C. Standards of Care requires dogs be released from containment at least daily.

Part 2, Division 2, section 12 of the regulation requires that each dog be released from his or her containment area at least once every 24 hours for exercise and socialization unless the dog is ill, injured, weather conditions make it unsafe, the dog is an extremely young puppy (less than 6 weeks old), or the dog is a bitch either near to whelping or has recently whelped a litter.  There is also an exception granted for dogs that have been run the day before, if that dog requires rest. 

I frequently allow my dogs to play ‘run amok’ in the yard, but it is almost never every single dog and, except during the ‘off season’ when the increased mental stimulation is needed, it is rarely every single day.  More commonly I allow groups of 2 to 6 dogs to run about, and though everyone gets a turn, these sessions are usually provided every third or fourth day. 

Every time we allow dogs to run free there is a risk of hostile interactions – in other words, dog fights.  Dog fights carry a huge risk of injury not only to the canine combatants, but also to the humans to attempt to break them up. 

I suspect this requirement was a politically driven ‘nod’ toward the animal rights crowd, as I’m not aware of any scientific evidence showing that daily free-run time is beneficial, especially for dogs housed in a manner that allows them to interact with at least some of their team mates whenever they wish to do so.

Many of the BC Standards of Care are difficult and perhaps impossible to enforce.

Less than 24 hours after the new regulations were released and enacted, Marcie Moriarty, the B.C. SPCA’s manager of animal-cruelty investigations, called the regulations a good first step in protecting the health and safety of sled dogs, but complained about inadequate funding to enforce the regulations.  “While the regulation is definitely a great tool to be using in investigations, it will be impossible for 25 constables funded by SPCA donors to be enforcing and regulating this industry on top of the 7,000 com-plaints we already respond to each year,” she said. “The government’s left a gap there.”

Even an adequately funded enforcement agency would find it impractical to determine whether or not a musher is feeding, picking up feces or releasing dogs from their containment areas every 24 hours.  To be enforceable the enforcement officer would have to put the kennel under 24 hour a day surveillance, which is rarely justified or affordable.

Many of the standards have no measurable or objective description, making interpretation of the regulations difficult.  For example, Part 2, Division 1, section 3, subsection 2 requires kennel operators to “ensure that each sled dog in a containment area has sufficient opportunities to engage in species-typical behaviours.”, but does not define what is, or is not, considered sufficient.

The B.C. Standards of Care and Code of Practice unfairly singles out dog mushers to the exclusion of all other dog owners.

My first concern is that the Province of British Columbia defines the sport of dog mushing as an industry, and feels the need to regulate the use and care of sled dogs differently than they do the use and care of any other dogs.  Part 1, division 1 of the Sled Dog Standards of Care defines “sled dog activities” as “…the keeping and use of, or the breeding of, a sled dog, for dog-powered or load-bering activity, including pulling (a) a person on skis or in or no a vehicle or any other mechanism (b)a vehicle or weight, whether over snow, on dry land or in another environment.  Part 1, division 2 defines the legal status of sled dog activities by stating “Sled dog activities are prescribed as regulated activities for the purposes of the (Provincial Cruelty to Animals) Act.” 

There is no reason to believe that sled dogs require any sort of care or consideration that is different from any other types of dogs.  Pet dogs, herding dogs, guardian dogs, service dogs, ALL dogs have the same physical and psychological requirements, yet all of them are apparently exempt from regulation by the Province.  Even the new B.C. Code of Practice acknowledges this fact by stating “Although this Code of Practice is designed for sled dog owners, the working group feels strongly it can apply to all persons responsible for the welfare of dogs, including dog breeders, those who show dogs, keep dogs as companions [pets], and use dogs for sport, as working animals, or for any other reason.”

My feeling is that if the Code can apply to all persons, then it SHOULD apply to all persons.

General Summary: 

I found very little in either the B.C. Sled Dog Standards of Care or Sled Dog Code of Practice that is contrary to either the voluntary Mush with P.R.I.D.E. Sled Dog Care Guidelines or common practices of dog mushers throughout the North America.   The B.C. regulations include provisions which I feel should also be included in the standards of care currently being developed for Alaska.  While the release from containment provision seems a bit much, especially for a musher who must work away from his or her kennel during a substantial portion of the day, and some of the regulations are simply impractical or impossible to enforce, most of BC’s new regulations seem to represent the high standard of care that most mushers already routinely provide.

On the other hand, I’m not a big fan of writing a law unless there is a very clear need for the law.  A single incident perpetrated by a single individual doesn’t necessarily indicate a wide-spread problem requiring legislative or bureaucratic intervention regardless of how wide-spread the public reaction might be.  Although abuse and neglect of dogs by mushers does occur from time to time, such behavior is alleged far more often than it is substantiated. 
 
Poorly written laws drafted in a rush to meet some political agenda are the worst of the lot and I have it on good authority that the B.C. Standards of Care working group was indeed pressured to give speed a much higher priority than thoughtful deliberation and collaboration.  Unlike the Alaska process, I'm not aware of any opportunity for the public to provide input into the B.C. process at all.  The result is regulations written by The Chosen Few that are likely to prove impractical or perhaps even impossible to effectively enforce.

In their haste, the working group borrowed very heavily from the Mush with P.R.I.D.E. Guidelines, and for that I am please and proud that they found the information useful.  I do wish they had acknowledged the source of the information upon which they so obviously relied upon. 

I’m especially concerned that the adoption of these regulations by the Province of British Columbia will prompt other jurisdictions in North America to jump onto a regulatory bandwagon, each competing against all the others to enact stiffer and stiffer laws in a game of political and bureaucratic one-upmanship. If so it is likely that vocal animal rights activists dedicated to eliminating all human interactions with animals will attempt to highjack the various regulatory processes and demand regulations so onerous that most mushers will no longer be able to afford either the money or time required to comply.  No matter how well meaning they may be, politicians and bureaucrats are far more responsive to political pressure than they are to the actual needs of those they regulate. 


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