IS THE BRITISH GOVERNMENT SECRETLY SLIPPING MANDATORY PET VACCINATION INTO LAW?
The CIEH have now published their Model Licence Conditions (MLCs).
If the DEFRA proposal is upheld, then these conditions could be made mandatory by law in all kennels in England.
The full MLCs and the PWA guidance document can be viewed below:
If the DEFRA proposal is upheld, then these conditions could be made mandatory by law in all kennels in England.
The full MLCs and the PWA guidance document can be viewed below:
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Currently local authorities are able to set vaccine requirements in their local kennels on a discretionary basis. This – we believe - is about to change, and mandatory vaccination will be the norm. As pet owners you could be forced to vaccinate against your wishes or to use vaccines that may have safety issues.
The UK government department DEFRA (Department for Environment, Food and Rural Affairs), has issued a consultation document on Animal Health and Welfare – Review of Animal Licensing. This is a proposal that could instigate licensing conditions under the Animal Welfare Act 2006.
Public consultation is a regulatory process by which the public's input on matters affecting them is sought. Its main goals are in improving the efficiency, transparency and public involvement in large-scale projects or laws and policies. The UK government has issued the Animal Health and Welfare – Review of Animal Licensing, but an important part of the consultation is being decided behind closed doors. This is the Chartered Institute of Environmental Health ‘Model Licensing Conditions’ – which we are not being invited to discuss. Our concern is that mandatory pet vaccination could be implemented, leaving owners with no right to choose whether they vaccinate or not or, indeed, how often they must vaccinate their pets or with which vaccines.
The consultation covers a range of licensing topics over fifteen questions. Whereas the PWA has answered all questions, we have focused on question two as this could make unnecessary over-vaccination mandatory in UK kennels, catteries, and home boarding establishments.
What is being proposed?
Question 2 (section 7 in the online consultation) is: To what extent do you agree or disagree with the proposal to promote or require use of the Model Conditions by local authorities, for activities where they have been agreed?
The Model Conditions they refer to are set by the Chartered Institute of Environment Health (CIEH). This is an organisation quoted as representing the interests of the environmental health profession – which includes industry.
Throughout 2015 we lobbied the CIEH with regard to their upcoming new conditions for boarding establishments, but we were excluded from any input and any influence we sought was rebuffed. They clearly don’t want input from those who must pay for and over-vaccinate their dogs. The CIEH delayed their response to us until after they had already agreed their new conditions, did not include scientific justification, and clearly sought to deflect from the issues especially as they did not even provide a reply to our main question.
What does this mean for our pets?
If DEFRA’s proposal to include CIEH conditions is approved this will mean that an unaccountable body (that represents industry, and probably the vaccine industry) will have the go ahead to enforce (among other conditions) their vaccination protocol in all boarding establishments in the UK – BY LAW. We use the word ‘probably’ because the CIEH working group members have been kept a secret from us. So we don’t know if the vaccine industry is directly involved, or whether individuals or groups that benefit financially from the industry are involved.
Regulations, enforceable by law, through the back door – unaccountable, unjustified, and undemocratic!
What can we do?
We have submitted our response to the consultation, that you can see in full here, and have asked all our supporters to respond also (and tell others about this).
Consultation progress can be monitored at:
With regard to the consultation question two (section 7 in the online consultation), about whether you agree or disagree with using Model Conditions, we have submitted a number of pages. However, the main points are:
1. We strongly disagree.
2. This response is in accordance with the Animal Welfare Act 2006, specifically with regard to the issue of over-vaccination that would be contrary to the Act, in that the proposal may enforce conditions where animals receive unnecessary vaccination that is of no benefit, but may cause harm.
3. The CIEH has been chosen for the purpose of providing licensing conditions for local authorities, but it excludes the input from pet owners, vets, and organisations that offer a differing view based upon solid science.
These collectively represent a significant body of opposition.
4. The CIEH and/or its working party members:
5. The CIEH is not accountable. Its recommendations will not be scrutinised under government consultation. However, their recommendations, if slipped through under cover, could become law without due democratic process. This robs pet owners of the fundamental right to freedom of informed choice.
6. Should a vaccine that is mandated under the CIEH model be subject to safety concerns, and we are all forced to use the vaccine, this amounts to being forced to harm our pets. This would be contrary to the Animal Welfare Act 2006 and European Law.
7. If Defra’s Consultation Process is to be of any value or integrity, it must incorporate the views of pet owners. Since the CIEH has refused to do this, the CIEH should not be allowed to set the agenda. This is highly undemocratic.
The UK government department DEFRA (Department for Environment, Food and Rural Affairs), has issued a consultation document on Animal Health and Welfare – Review of Animal Licensing. This is a proposal that could instigate licensing conditions under the Animal Welfare Act 2006.
Public consultation is a regulatory process by which the public's input on matters affecting them is sought. Its main goals are in improving the efficiency, transparency and public involvement in large-scale projects or laws and policies. The UK government has issued the Animal Health and Welfare – Review of Animal Licensing, but an important part of the consultation is being decided behind closed doors. This is the Chartered Institute of Environmental Health ‘Model Licensing Conditions’ – which we are not being invited to discuss. Our concern is that mandatory pet vaccination could be implemented, leaving owners with no right to choose whether they vaccinate or not or, indeed, how often they must vaccinate their pets or with which vaccines.
The consultation covers a range of licensing topics over fifteen questions. Whereas the PWA has answered all questions, we have focused on question two as this could make unnecessary over-vaccination mandatory in UK kennels, catteries, and home boarding establishments.
What is being proposed?
Question 2 (section 7 in the online consultation) is: To what extent do you agree or disagree with the proposal to promote or require use of the Model Conditions by local authorities, for activities where they have been agreed?
The Model Conditions they refer to are set by the Chartered Institute of Environment Health (CIEH). This is an organisation quoted as representing the interests of the environmental health profession – which includes industry.
Throughout 2015 we lobbied the CIEH with regard to their upcoming new conditions for boarding establishments, but we were excluded from any input and any influence we sought was rebuffed. They clearly don’t want input from those who must pay for and over-vaccinate their dogs. The CIEH delayed their response to us until after they had already agreed their new conditions, did not include scientific justification, and clearly sought to deflect from the issues especially as they did not even provide a reply to our main question.
What does this mean for our pets?
If DEFRA’s proposal to include CIEH conditions is approved this will mean that an unaccountable body (that represents industry, and probably the vaccine industry) will have the go ahead to enforce (among other conditions) their vaccination protocol in all boarding establishments in the UK – BY LAW. We use the word ‘probably’ because the CIEH working group members have been kept a secret from us. So we don’t know if the vaccine industry is directly involved, or whether individuals or groups that benefit financially from the industry are involved.
Regulations, enforceable by law, through the back door – unaccountable, unjustified, and undemocratic!
What can we do?
We have submitted our response to the consultation, that you can see in full here, and have asked all our supporters to respond also (and tell others about this).
Consultation progress can be monitored at:
- https://consult.defra.gov.uk/animal-health-and-welfare/consultation-on-the-review-of-animal-licensing (where you can also see DEFRA’s consultation letter and document).
- Please also forward this PWA alert, or the link to it on our website, to as many people as you can – on email, on twitter, on Facebook, other social media, or any other way possible, and ask them to do the online survey.
With regard to the consultation question two (section 7 in the online consultation), about whether you agree or disagree with using Model Conditions, we have submitted a number of pages. However, the main points are:
1. We strongly disagree.
2. This response is in accordance with the Animal Welfare Act 2006, specifically with regard to the issue of over-vaccination that would be contrary to the Act, in that the proposal may enforce conditions where animals receive unnecessary vaccination that is of no benefit, but may cause harm.
3. The CIEH has been chosen for the purpose of providing licensing conditions for local authorities, but it excludes the input from pet owners, vets, and organisations that offer a differing view based upon solid science.
These collectively represent a significant body of opposition.
4. The CIEH and/or its working party members:
- Are subject to conflicts of interest.
- Have not provided scientific justification for their views regarding conditions.
- Include views that are contrary to their activities/guidance outside the scope of the CIEH (say one thing and do another).
- Provide views that are in direct opposition to the views of the WSAVA VGG and hundreds of veterinary practices, and thousands of dog owners in the UK.
5. The CIEH is not accountable. Its recommendations will not be scrutinised under government consultation. However, their recommendations, if slipped through under cover, could become law without due democratic process. This robs pet owners of the fundamental right to freedom of informed choice.
6. Should a vaccine that is mandated under the CIEH model be subject to safety concerns, and we are all forced to use the vaccine, this amounts to being forced to harm our pets. This would be contrary to the Animal Welfare Act 2006 and European Law.
7. If Defra’s Consultation Process is to be of any value or integrity, it must incorporate the views of pet owners. Since the CIEH has refused to do this, the CIEH should not be allowed to set the agenda. This is highly undemocratic.