SimonD
Active member
Some may recall a discussion on the YM Scuttlebutt forum back on March on the subject of bringing dogs back into the UK from abroad. In brief, there was something of a consensus that the current Pet Passport scheme as generally ineffective. I undertook to ask some questions of Defra and write to the Secretary of State. The answers to my questions reveal that the Animal Health and Veterinary Laboratories Agency have very little information on the effectiveness of the current Pet Travel Scheme and no information relating to boat owners.
It was suggested that some forumites might wish to add their names to a letter seeking change. You might consider adding your name if you would welcome the facility to take your pet overseas (and return it) or if you are concerned with the increased risk to bio-security that the current arrangements pose. If you would like to do so, please pm me with your name and address and I'll add to the letter. The letter reads:
The Rt Hon Owen Paterson, MP
Secretary of State for Environment, Food and Rural Affairs
Nobel House
17 Smith Square
London
SW1P 3JR
Dear Secretary of State
I write to raise concern regarding the potential risk to bio-security posed by private boat owners returning pets from overseas, and to propose a way forward.
It is apparent that a significant number of private boat owners routinely carry their pets on board. Many of these often sail abroad and would want to take their pets. (An estimate of the potential numbers is set out in an annex to this letter.)
The present Pet Travel Scheme, which requires the use of an approved carrier, makes it impractical for a boat owner to return their pet to the UK. Very few, if any, approved cross channel carriers permit foot passengers. This means that a third party would need to travel from the UK to collect the pet and return. Apart from the expense, this poses a number of practical difficulties related to the uncertainties inherent in sailing. Hence, in reality, it is impractical for boat owners to return their pets to the UK using an approved carrier.
If, as a consequence, a boat owner considered ignoring the requirement to use an approved carrier, they would be extremely unlikely to be apprehended. It is apparent that a private vessel entering the UK could arrive at any one of a number of marinas, ports or anchorages and any time of the day or night. The chances of detecting a pet being landed are therefore minimal. Furthermore, to bring a successful prosecution, the relevant local authority would have to show that the animal had been landed overseas. This would be extremely difficult to evidence, as noted by the RSPCA.
In its recent report, "Pushing at an open door – how the present UK controls on rabies are failing", the RSPCA states:
"Under the Rabies Order 1974 an inspector from the local authority can declare that a dog has been illegally imported and is a rabies risk if they have “reason to believe it has been landed ...in contravention of this order”. However uncertainty exists amongst local authorities over the test needed to satisfy this condition and the RSPCA has found that local authorities are reluctant to declare a dog as illegally imported when they are not clear what proof is required."
This picture of ineffective enforcement is borne out by the fact that since January 2012, there have been only three prosecutions under the Rabies (Importation of Dogs, Cats and Other Mammals) Order 1974. One of these was in respect of KLM flying a dog into the UK from Mexico; the other two were illegal puppy traders who were only discovered when imported dogs were purchased and examined by a vet.
This combination of the impracticality of compliance and the negligible risk of detection creates a perverse incentive to not comply with the requirements of the Pet Travel Scheme. This creates an increase in the threat to UK bio security. Because of the ineffective enforcement and potential numbers involved, I would argue that this is a significant risk warranting a change to the current arrangements.
I suggest that the change required is not to tighten enforcement; this would be disproportionate in terms of cost and effort and has no guarantee of being more effective. Instead, an arrangement which makes it easier for boat owners to comply with requirements would incentivise compliance.
I envisage that such an arrangement would be to retain all the current requirements of the Pet Travel Scheme, excepting the need to use an approved carrier. Instead, owners of private leisure vessels would be required to notify an approved authority on arrival in the UK, and before landing their pet. The approved authority would then carry out the same checks that are currently performed by approved carriers before boarding. The approved authority could be a local veterinary surgeon, port authorities or marina staff. They would need to be approved by your Department and have the same facilities as approved carriers.
This arrangement would be effectively the same as the current arrangements, but simply move the point of inspection from pre-boarding before travel to pre-landing on arrival. The key difference would be that it would be much easier for private boat owners to comply with. Hence, the potential risk to bio-security would be much reduced.
Discussions with other boat owners, leads me to believe that the sort of change proposed would be welcomed. I append the details of those I have contacted who support the content of this letter.
The Royal Yachting Association and Cruising Association represent a large number of boat owners and may have a view on this issue. I have, therefore, sent a copy of this letter to these bodies.
I hope you find merit in this proposal and are able to respond positively. I look forward to your reply.
Yours sincerely
It was suggested that some forumites might wish to add their names to a letter seeking change. You might consider adding your name if you would welcome the facility to take your pet overseas (and return it) or if you are concerned with the increased risk to bio-security that the current arrangements pose. If you would like to do so, please pm me with your name and address and I'll add to the letter. The letter reads:
The Rt Hon Owen Paterson, MP
Secretary of State for Environment, Food and Rural Affairs
Nobel House
17 Smith Square
London
SW1P 3JR
Dear Secretary of State
I write to raise concern regarding the potential risk to bio-security posed by private boat owners returning pets from overseas, and to propose a way forward.
It is apparent that a significant number of private boat owners routinely carry their pets on board. Many of these often sail abroad and would want to take their pets. (An estimate of the potential numbers is set out in an annex to this letter.)
The present Pet Travel Scheme, which requires the use of an approved carrier, makes it impractical for a boat owner to return their pet to the UK. Very few, if any, approved cross channel carriers permit foot passengers. This means that a third party would need to travel from the UK to collect the pet and return. Apart from the expense, this poses a number of practical difficulties related to the uncertainties inherent in sailing. Hence, in reality, it is impractical for boat owners to return their pets to the UK using an approved carrier.
If, as a consequence, a boat owner considered ignoring the requirement to use an approved carrier, they would be extremely unlikely to be apprehended. It is apparent that a private vessel entering the UK could arrive at any one of a number of marinas, ports or anchorages and any time of the day or night. The chances of detecting a pet being landed are therefore minimal. Furthermore, to bring a successful prosecution, the relevant local authority would have to show that the animal had been landed overseas. This would be extremely difficult to evidence, as noted by the RSPCA.
In its recent report, "Pushing at an open door – how the present UK controls on rabies are failing", the RSPCA states:
"Under the Rabies Order 1974 an inspector from the local authority can declare that a dog has been illegally imported and is a rabies risk if they have “reason to believe it has been landed ...in contravention of this order”. However uncertainty exists amongst local authorities over the test needed to satisfy this condition and the RSPCA has found that local authorities are reluctant to declare a dog as illegally imported when they are not clear what proof is required."
This picture of ineffective enforcement is borne out by the fact that since January 2012, there have been only three prosecutions under the Rabies (Importation of Dogs, Cats and Other Mammals) Order 1974. One of these was in respect of KLM flying a dog into the UK from Mexico; the other two were illegal puppy traders who were only discovered when imported dogs were purchased and examined by a vet.
This combination of the impracticality of compliance and the negligible risk of detection creates a perverse incentive to not comply with the requirements of the Pet Travel Scheme. This creates an increase in the threat to UK bio security. Because of the ineffective enforcement and potential numbers involved, I would argue that this is a significant risk warranting a change to the current arrangements.
I suggest that the change required is not to tighten enforcement; this would be disproportionate in terms of cost and effort and has no guarantee of being more effective. Instead, an arrangement which makes it easier for boat owners to comply with requirements would incentivise compliance.
I envisage that such an arrangement would be to retain all the current requirements of the Pet Travel Scheme, excepting the need to use an approved carrier. Instead, owners of private leisure vessels would be required to notify an approved authority on arrival in the UK, and before landing their pet. The approved authority would then carry out the same checks that are currently performed by approved carriers before boarding. The approved authority could be a local veterinary surgeon, port authorities or marina staff. They would need to be approved by your Department and have the same facilities as approved carriers.
This arrangement would be effectively the same as the current arrangements, but simply move the point of inspection from pre-boarding before travel to pre-landing on arrival. The key difference would be that it would be much easier for private boat owners to comply with. Hence, the potential risk to bio-security would be much reduced.
Discussions with other boat owners, leads me to believe that the sort of change proposed would be welcomed. I append the details of those I have contacted who support the content of this letter.
The Royal Yachting Association and Cruising Association represent a large number of boat owners and may have a view on this issue. I have, therefore, sent a copy of this letter to these bodies.
I hope you find merit in this proposal and are able to respond positively. I look forward to your reply.
Yours sincerely
