Exclusive: Summary of the KC’s Regulatory Impact Assessment on Mutilations Regulation
THE KENNEL Club has hit back at Ron Henney’s suggestion that they should conduct an Impact Assessment on the effects of a tail docking ban, pointing out that they had produced just such a document in the autumn of 2005, and that Mr Henney had been made aware of this fact.
Phil Buckley, the KC’s External Affairs Manager told OUR DOGS: "In September 2005, the Kennel Club did produce a 'Regulatory Impact Assessment' (RIA) for Defra with regard to the docking issue. Mr Henney is well aware of this fact as he has recently been in contact with the Kennel Club and we have confirmed this to him.
"We have not made the document public knowledge at the time, as we felt that Defra would appreciate the opportunity to consider our evidence, without having to also fight a PR rear guard action. This is an extremely important issue for the KC and we wanted to handle the RIA correctly and not lose credibility with Government and ensure that they fully consider the facts."
Earlier this week, the KC exclusively spoke to OUR DOGS regarding the RIA document and summarised their findings for our readers.
The KC’s Impact Assessment on Mutilations Regulation contains a wealth of annotated detail regarding the various facets of docking. The document states:
For over a decade the Kennel Club has been receiving feedback from breeders involved with docked breeds stating that should docking be proscribed by Government, then they will stop breeding dogs altogether. Experience in countries such as Sweden and the Netherlands has shown that this is likely to be the case.
As regards the financial impact this would have on industry, breeders and dog owners, the Kennel Club has supplied Defra with detailed figures of the registrations of traditionally docked breeds, which are based on the assumption that all breeders of traditionally docked breeds will stop breeding puppies if docking becomes illegal. While this is an unlikely assumption, it is impossible to estimate exactly what percentage of breeders will continue to breed traditionally docked dogs.
However, breeder and breed club correspondence with the Kennel Club suggests that if a ban on tail docking were enforced (even with an exemption for working dogs), many breeders would stop breeding traditionally docked breeds, which would result in income from registrations falling dramatically, thus affecting the income of the KC.
Breeders: The KC has estimated that breeders sell approximately 70% of puppies and their prices range widely, with an average of, say, £450 per puppy. If a ban were to be enforced, this would collectively cost the breeders who sell puppies many millions of pounds. If as a result of the ban, a dog that a breeder kept injured its undocked tail, this would also have a financial impact on the breeder in terms of veterinary bills (see below).
Turning to the financial impact that a docking ban would have on a dog owner, the Assessment points out that for some dog owners the ban will have no financial impact; whilst for some dog owners the price of their favourite breed of dog may increase as they become rarer. Crucially, it points out that for many dog owners a ban on docking would have a financial impact in terms of veterinary bills if their dog injured its undocked tail. The document continues:
One dog owner contacted the Council of Docked Breeds to give an example of how much a ban on docking could cost dog owners if their dog injured its tail:
The cost of treating one dog’s tail problems were as follows:
12 May 2000 –
initial consultation and antibiotics
16 May 2000 –
surgery to remove 4 inches and
16 May 2000 & July 2000 –
consultations, dressings and
17 July 2000 –
surgery to remove remainder
of tail and medication
Memorandum submitted to the Environment, Food and Rural Affairs Select Committee from Dr Peter Shaw in August 2004 also states that: "A damaged wagging tail can produce havoc by throwing blood about through centrifugal action and it is difficult to bandage. In general a dog will bite at a damaged tail, especially if bandaged, so that treatment also involves the use of large conical head collars or muzzles to prevent this…In the worst cases tail amputation is necessary, and dogs then need to wear collars for up to six weeks during which the owner has to stay with dogs when they are fed (with muzzle or collar off). The cost of such an accident can run into several hundreds of pounds".
Studies that conclude tail injuries not to be uncommon clarify that some dog owners will inevitably face higher veterinary bills if a ban on docking is enforced:
In 2002 the Metropolitan Police Dog Training School provided the Kennel Club with statistics on how many dogs had to be docked over two years because of tail injuries. The veterinary surgeon who carried out the amputations reported that in 2001, 4 undocked dogs needed to have a full amputation and 1 partially amputated tail needed full amputation. Between January and May 2002, 4 undocked dogs needed to have a full amputation.
A statistical summary produced by the Kennel Club reinforced the premise that the majority of working gundogs were docked, as over 98% of the 763 working gundogs surveyed were docked.
However the survey still showed that of the small percentage of those undocked, a high proportion suffered tail damage – with 75% of Clumber Spaniels, 20% of English Springer Spaniels and 25% of Wirehaired Vizsla’s all suffering damage. The Kennel Club does not agree with the Government’s current position that tail docking should be banned, even if working dogs would be exempt from this ban.
The Kennel Club believes legislation to this effect is unnecessary considering it allows customarily docked breeds to be shown with or without their tails, and the Kennel Club Breed Standards reflect this. For the past five years the Kennel Club Breed Standards and Stud Book Committee has liaised closely with individual Breed Clubs and Councils in order to amend the Breed Standards by adding a full tail clause for those breeds which are customarily docked.
Answering the Government’s question whether it anticipated that demand for docked dogs would decline, or would whether they anticipated an import market developing, the KC’s answer at the conclusion of the Docking segment of the Assessment was unequivocal:
While it is difficult for the Kennel Club to estimate market changes, Quentin L. LaHam Ph.D, Titular Professor, (retired) claimed "In my view this law will so negatively affect the breeds concerned, as to effectively eliminate them from international competition and could bring about great hardship upon individual dogs…Certainly, those breeds concerned stand a serious chance of going into decline and international exchange will have an influence on the export of these breeds".