Animal Care Neglected in Lockdown Regulations – Press Statement

The South African Veterinary Association (SAVA) represents more than 60% of all veterinarians in South Africa and is celebrating its centenary year in 2020.

In the Lockdown Regulations, published on the 25th of March 2020 Veterinary Services and Animal Care have been classified as essential services. The subsequent release of the Regulations on the 29th of April further emboldened the Veterinary Services and Animal Care as being included in services
allowable under Level 4 of the Regulations.

SAVA has noted, with concern, that the lack of clarity provided for both definitions of Veterinary Services and Animal Care has yielded confusing interpretations of the terms. SAVA, along with the South African Veterinary Council (the regulatory body for veterinary and para-veterinary professions) and the Chief Veterinary Officer the Department of Agriculture, Land Reform and Rural Development developed guidelines for Veterinary Services to assist in determining whether particular services are deemed to be essential or could be postponed without undue risk to the health and welfare of animals.

Confusion surrounding the definition of Animal Care still remains. To understand the frame of reference to define Animal Care appropriately, it is necessary to use an international perspective. The World Organisation for Animal Health, formerly the Office International des Epizooties (OIE) is
an intergovernmental organisation, of which South Africa is a member country. One of the objectives of the OIE is to promote Veterinary Services and Animal Welfare.

The OIE Terrestrial Animal Health Code (the Terrestrial Code) provides standards for the improvement of terrestrial animal health and welfare and veterinary public health worldwide. It is available in the public domain and can be found here: https://www.oie.int/en/standardsetting/
terrestrial-code/access-online/.

The latest edition of the Terrestrial Code was adopted in the 87th General Session in May 2019.

The Terrestrial Code provides a statement on animal welfare and animal care and is appropriate to quote in its entirety (emphasis added by writer):

“Animal welfare means the physical and mental state of an animal in relation to the conditions in which it lives and dies.

An animal experiences good welfare if the animal is healthy, comfortable, well-nourished, safe, is not suffering from unpleasant states such as pain, fear and distress, and is able to express behaviours that are important for its physical and mental state.

Good animal welfare requires disease prevention and appropriate veterinary care, shelter, management and nutrition, a stimulating and safe environment, humane handling and humane slaughter or killing. While animal welfare refers to the state of the animal, the treatment that an animal receives is covered by other terms such as animal care, animal husbandry, and humane treatment.”

In the Terrestrial Code, the OIE further recognises the “five freedoms” of animals that provide valuable guidance in animal welfare. These are freedom from hunger, thirst and malnutrition, freedom from fear and distress, freedom from physical and thermal discomfort, freedom from pain, injury and disease and freedom to express normal patterns of behaviour.

In the Animal Protection Act 71 of 1962 (as amended), Section 2(1)(r) reads as follows: “Any person who by wantonly or unreasonably or negligently doing or omitting to do any act or causing or procuring the commission or omission of any act, causes unnecessary suffering to any animal

Shall, subject to the provisions of this Act and by any other law, be guilty of an offence and liable on conviction to a fine or imprisonment”.

In guidelines published by the Department of Agriculture, Land Reform and Rural Development states that Animal Welfare enforcement is an essential service in every level of Lockdown. To be compliant with Animal Welfare, it is therefore required to perform the requisite services to ensure animals exercise their right to enjoy the “five freedoms”.

SAVA wishes to announce its position on Animal Welfare and Animal Care activities.

1. Any action or inaction by a service provider or owner whether, directly or indirectly, to a particular animal or a group of animals resulting in any of the  “five freedoms” being negatively impacted, constitutes a breach of the Lockdown Regulations, the Animal Protection Act and the OIE Terrestrial Code.

2. These actions or inactions must be measured against the spirit and intent of the COVID-19 response of South Africa and must be performed with appropriate measures in place, e.g. social distancing and the use of personal protective equipment.

3. These services include (but not limited to) grooming parlours (performing services that if not performed, would expose the animal to fear and distress, physical and thermal discomfort, pain, injury or disease), farrier services, animal dentistry, acupuncture, animal physiotherapy and behaviour therapy.

4. We have noted an increase in animals being placed with animal shelters during the lockdown period for reasons that may include the change in economic or physical circumstance to care for the animal. Animal shelters have limited physical space and cannot accommodate all animals without re-homing or placing animals in foster care. Should rehoming or fostering of animals not be allowed, it will place animal shelters in an impossible situation to either not accept further animals, effectively abandoning them or euthanising otherwise healthy animals to create space. There is a public health risk associated with a large unsheltered animal population, being dog bites and zoonotic transmission, environmental health and physical health.

The lack of communication and clarity in the public domain has yielded concerning results. The interpretation of law enforcement officials of the Regulations has resulted in threatening action against individuals that are baseless in law and fact.

SAVA requests to be consulted in the drafting of lockdown regulations related to veterinary services and animal care. SAVA further requests that there is transparency with regards to the information used in decision-making to set regulations regarding animal care and welfare.

Contact Person: Gert Steyn, Managing Director, SAVA md@sava.co.za

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