Saturday, August 10, 2013

Enquiry into the RSPCA? - Part 6: equines

The desire to improve the lives of horses was at the core of the RSPCA's original foundation, with all of the founders being passionately concerned for their welfare in spite of differing views on how this might be achieved.

As large, charismatic mammals who are highly visible, horses are responsible for a large number of complaints about the RSPCA's inaction in the face of conditions which are not quite bad enough to be illegal.  Animals who are not in fact suffering any welfare issues may be the subject of complaints if members of the public do not appreciate that native ponies are adapted to life outside during the winter (and may indeed be more likely to have problems in very hot weather or when unnaturally rich grass pasture is available).

Horses are also the subject of high-profile debate about acceptable working conditions and sporting events with a high degree of risk.

At one end of the scale there are native moorland ponies and ponies grazed by travellers on pieces of rough ground. The RSPCA may be pressed to take action when they are at risk in adverse weather conditions and also if pony owners dispose of surplus animals to the horsemeat trade.

At the other extreme are high-value sport horses who may be at risk of fatal accidents (e.g. in jump racing) and may be kept in restrictive conditions which do not satisfy their behavioural needs. If they cease to be valuable because of age or injury they may also be disposed of to the meat trade or may enter a downward spiral of less and less competent owners.

They are extremely expensive to care for and raise the ethical dilemma of what to do with animals who have been rescued but may never be fit enough to be placed in a normal working home.

The RSPCA attempts to place unrideable horses as companions, thereby incurring some criticism that this is a sentimental waste of funds.

What an enquiry might comment

In many ways the RSPCA's difficulties in coping with the current equine welfare situation mirror its problems with dogs in that there is a high demand for it to take action in situations where it has limited ability to do so, either because there are no legal powers to act or because it is limited by resource constraints.

If the legal position on horses left on grazing land without the owner's permission and horses straying on the highways is changed to permit landowners to dispose of animals there will probably be pressure for the RSPCA to take them in to prevent them from being euthanised. It is difficult to see how the society will cope unless more people are prepared to give practical or financial support.

Enquiry into the RSPCA? - Part 5: Laboratory animals

During most of its existence the Society has taken a relatively pragmatic view of animal experimentation, accepting that most people will put human health above animal suffering and pressing for reform rather than abolition. It accepts the general scientific consensus on the validity of animal experiments and promotes the moral imperative to reduce animal use to the minimum compatible with medical progress.

In the past this has sometimes brought it into conflict with scientists unwilling to accept any legal limits on science. However the question of experiments has been significant as yet another position on which the Society's "gatekeeper" position has made it a target for campaigners who will accept nothing less than the abolition of animal use.

What an enquiry might comment

The RSPCA's comparatively modest position on experiments has probably enabled it to be more effective than other organisations who cannot engage with the political process because it is plain that no reform will be enough to satisfy them.

It is a pity that recent changes in the society, intended to reduce "back office" costs which will appear as administration on the balance sheet, have diminished the strength of the Science Group. Donors should be encouraged to understand the importance of this apparently unexciting area of the Society's work and give it more support.

The RSPCA's work to reduce animal suffering in experiments rarely hits the headlines, but its research animals department plays an influential role in many bodies.

Friday, August 9, 2013

Enquiry into the RSPCA? - Part 4: Wild animals

Wild animals have been a source of contention for the RSPCA ever since it was founded in 1824. It is known that two of the major original founders (Arthur Broome and Lewis Gompertz) were opponents of fox-hunting and two (Richard Martin and Thomas Erskine) were themselves hunters, although Martin seems to have had some doubts about its legitimacy towards the end of his life.

During the RSPCA's first hundred years the hunting question does not seem to have caused serious difficulties because there were other animal welfare concerns which were clearly more urgent. However during the 20th century opposition to hunting became progressively more insistent. Both sides viewed the RSPCA as the gatekeeper to legislation; provided the RSPCA remained neutral or opposed a ban no government would give parliamentary time to a hunting bill.

Thus, the anti-hunt lobby came to view the RSPCA with nearly hysterical loathing, and it was extremely tempting for the pro-hunt faction to try to push the Society beyond a view that, although hunting was cruel, there were worse abuses, into positive opposition to a hunt ban. Once opposition to hunting with dogs had become RSPCA policy the pro-hunters became equally hysterical in their hatred of the Society. Unfortunately there was often no corresponding change in the views of many anti-hunters, who still saw the RSPCA as an obstacle to radical change in the way animals are treated.

Wildlife Hospitals

Parallel to the issue of legal protection for wild animals there was the question of rescue of injured or sick wild animals. As individuals viewed as animal welfare experts the inspectors were commonly asked to help. This might be relatively straightforward if an uninjured animal could simply be freed and released or if one was clearly so ill that mercy killing was the only option (for example in the case of rabbits with myxomatosis). However it was more difficult if a wild animal was potentially salvageable (for example oiled seabirds) but only if longer-term treatment and care was available.

Currently the RSPCA has four specialist wildlife centres (fully funded by the Central RSPCA not the local branches) and wild animals are included in their national agreement with vets. This states that vets should examine and give first aid to small wildife and birds free of charge during normal working hours while the RSPCA will include larger birds and mammals in its general scheme for provision of funding to cover first aid and will also pay for emergency treatment of small wildlife outside normal hours.

Treatment of sick/injured wildlife remains contentious to an extent as it is RSPCA policy that wild animals should be euthanased if they cannot be rehabilitated sufficiently to be returned to the wild.

What an enquiry might say

A relatively short period of time has elapsed since the passing of the Hunting Act and it may be that passions will eventually die down as those who were mainly interested in hunting in order to ride or watch hounds track find alternative ways to enjoy the outdoors.

Anti-RSPCA feeling has been sparked off again by a number of enforcement cases brought by the Society after a lull during which it seems that some people in the hunting camp were content to assume the law would not be strictly applied.

This has potentially serious implications for the much larger number of people who depend on the RSPCA's practical welfare services (which represent by far the largest part of its activities).

It might be helpful if the RSPCA were to re-examine whether some disabled (or simply too tame) wildlife could have a meaningful life in semi-natural conditions - for example in an enclosed deer park.

Thursday, August 8, 2013

Enquiry into the RSPCA? - Part 3: Farm animals

Animals who are kept to produce food or other products (wool, milk, eggs etc) for people or for other animals

Reform or abolition?

The RSPCA's Inspectorate will act to enforce animal protection law if farm animals are mistreated just as they do when the victims are companion animals, although they may refer complaints to the local Trading Standards or to DEFRA where they believe this is more appropriate.

As well as this law enforcement role, the RSPCA campaigns to change the law to provide more protection for farm animals and it operates a sophisticated farm assurance scheme, Freedom Food, which is designed to drive up welfare standards by providing a route by which farmers can get a premium for voluntary improvements.

The Society has commissioned an audit of the impact of the Freedom Food scheme by external scientific experts with a view to determining which aspects of the scheme have been effective in improving welfare in terms of the lifetime experiences of individual animals. The panel's report has now been published.

In addition to Freedom Food, the Society operates a "Good Business Awards" scheme to reward welfare innovation by individual businesses. This is able to be more adventurous than Freedom Food which is very much geared to what can be attainable in normal food producing activities rather than niche markets.

The RSPCA does not specifically promote a vegetarian or vegan lifestyle although many of its staff and supporters are themselves either vegetarian or vegan.

What an enquiry might comment

There is a segment of the animal protection movement which finds it utterly abhorrent that an animal welfare charity should involve itself in farming and would like the RSPCA to withdraw from Freedom Food and all similar activities. Some individuals with these views have devoted considerable effort to seeking out malpractice on Freedom Food farms and this may have been unintentionally useful to the scheme as it must leave farmers in no doubt that they will be found out if they only pay lip-service to welfare.

Publicity for "bad apples" in the scheme has been embarrassing for the RSPCA and they should probably look at extending unannounced checks on farms as well as the planned audits which are key to Freedom Food's function as a method of improving standard farming practice.

There is a fundamental tension between those who believe that killing and eating animals can never be compatible with welfare and those who accept that the wider society are probably always going to eat meat and wish to ensure that animals kept to produce food are treated as humanely as possible. Realistically this source of strife is not likely to disappear.

Any assessment of the value of the RSPCA to society at large needs to make allowances for the tendency for criticisms to come from those who believe it is not radical enough as well as those who think it has moved too far towards the arena of animal rights.

Enquiry into the RSPCA? - Part 2: Companion animals

Our pets - the animals who share our homes.

Rehoming and euthanasia

The RSPCA gives priority to animals taken in as a result of cruelty investigations or found as injured strays and it puts no time-limit on the length of time rehomeable animals may be cared for until they can be placed in a new permanent home. This means that centres are always full and need to be supplemented by paying for space in private boarding kennels and catteries or placing animals with volunteer foster carers.

In 2012 (most recent year for which figures are available) the RSPCA took in 18,355 dogs of which 11,356 were rehomed, and  6,817 were put to sleep because they were incurably ill, dangerous or belonged to breeds which it is illegal to rehome.  182 potentially rehomeable dogs were put to sleep.

The RSPCA does not normally taken in stray dogs as these are legally the responsibility of the Local Authority. However few Local Authorities provide a 24 hour 7 day per week collection service for stray dogs or pay for treatment of injured dogs whose owner is not known.

It is debatable whether the RSPCA can legally spend funds to provide a service which should by statute be the responsibility of a public body. It would probably not be treated as misuse of charity funds if the RSPCA were to collect stray dogs at times when no LA collection service is provided or if it were to pay for treatment of injured dogs where no LA funding is available. However this would be a significant drain on the Society's resources, even if activity by the Central Society was restricted to collecting dogs and providing funds for initial first aid treatment. 

If the process for continuing treatment of injured stray dogs was dealt with in the same way as the current handling of injured stray cats it would mean imposing a considerable strain on the local branches, many of whom are already struggling to remain solvent.

In 2012 the RSPCA took in 43,621 cats of which 30,202 were rehomed (or released after neutering if feral) and 12,607 were put to sleep because they were untreatably ill or injured. 812 potentially rehomeable cats were put to sleep.

In 2013 the Society began a revolutionary initiative to locate rehoming centres within Pets at Home stores in order to encourage adoption of rescue animals instead of commercial purchase. Selling animals is a very small element of the revenue of a pet store so there is excellent potential to drive down over-breeding while maintaining the stores' income from pet food and accessories.

What an enquiry might comment

The RSPCA have very low rates of euthanasia of healthy domestic pets—better than most comparable SPCAs in other countries. These rates could very probably be reduced to zero by spending relatively small amounts of money to increase available accommodation in private boarding kennels.

Vociferous claims that the RSPCA has extremely high euthanasia rates probably contribute to inefficiencies in transferring animals between locations in order to speed up rehoming. Each branch knows that it is saving every animal it possibly can and the emotional investment in those animals who have already been admitted makes it difficult to "let go" and send them elsewhere without guarantees that the centre receiving them will be equally dedicated.

Some newly recruited branch volunteers and national staff may be unsure about branch obligations to accept inspectors' intake other than prosecution cases and be unaware that by refusing animals they might be forcing an inspector to arrange euthanasia.

One option might be for the Central RSPCA to pay for short-term boarding to provide a breathing space in which options for transfer to other branches or to National rehoming centres could be investigated. A potential problem is that this would inevitably be misrepresented as the RSPCA having a policy of killing animals after 3 days (or whatever the breathing space was) even if these animals were always successfully transferred to other accommodation.

Sick and injured strays

The RSPCA is unique among animal charities in England and Wales in having a blanket agreement with private vets to pay £60 towards first aid for sick or injured animals whose owners cannot be traced.

Dogs are not normally included in this as the Local Authority is legally responsible for paying for immediate treatment of stray dogs but in practice the RSPCA will pay if it is impossible to contact the local council, a dog needs immediate treatment to prevent suffering and the veterinary practice absolutely refuses to provide treatment unless payment is guaranteed. This £60 is paid by the Central RSPCA and local branches will then cover the cost of further treatment if they are able.

What an enquiry might comment

Many of the complaints about the RSPCA relate to not collecting/treating stray dogs and dissatisfaction that the £60 payment for initial first aid treatment is not larger. There might be scope for a national arrangement with local authorities for the RSPCA to take over part of their statutory responsibility for stray dogs in return for payment as the RSPCA already has a 24 hour control centre taking calls from the public and personnel available during the night to collect animals. As the Society is already over-stretched this would only be possible if the arrangement provided full cost recovery to enable extra people to be employed.

Increasing the veterinary treatment payment per animal by £100 would be likely to cost in the order of £4 million and would only become possible if the Society significantly increased its income.

It is very unfortunate that the RSPCA has recently become the target of political campaigns which aim to force the RSPCA to change its campaigning policies by hitting the funding of its practical welfare work.

Wednesday, August 7, 2013

Digression on phones

Because our branch runs an animal clinic we have an obligation to be contactable in case one of our registered patients needs emergency treatment outside normal working hours. This can be a bit of a curse, witness a few nights ago when a gentleman who I think has some kind of learning difficulties, called me at 2 am to ask how long he should wait between applications of Stronghold (a flea treatment) and again at 3 to ask whether bathing his dog 48 hours after the first lot of Stronghold would have washed it off.

Fortunately most people want to sleep through the night themselves and consequently only phone when something really is  urgent. 

The reason why we have to take the out of hours calls rather than simply routing the phone to our veterinary provider is the percentage that are really nothing to do with the clinic—not only baby birds, but also people whose dogs have suddenly taken a hatred to one another; ones whose neighbours have barking dogs and so on.

It does give us an insight into what a really horrible job the operators at the RSPCA National Control Centre have. I wouldn't want to sit for eight hours being shouted at by strangers for all the tea in China. 

Inevitably, even with the relatively low number of calls we take here, there are people who take offence and people who are furiously dissatisfied that we can't offer more, or different help to solve their problems. When someone does complain it can be remarkably difficult to trace exactly who said what to whom and why, or whether someone completely misunderstood what they were being told. 

Enquiry into the RSPCA? - Part 1: Governance

The boring bit:

Who decides what the Society does?

The RSPCA is effectively a "family" of charities.

Firstly, there is the central RSPCA which determines major policy directions, runs the inspectorate, initiates prosecutions and provides facilities which are intended for use on a regional/national basis.

Secondly, there are 166 local branches (together covering England and Wales) which provide welfare services to their local area. This number varies from year to year as branches may split or merge.

When the RSPCA originally grew up, the purpose of a branch was to raise funds to pay the salary of their own local inspector.

Today the inspectors are paid for by the central RSPCA, but the branches are still expected to provide support services to enable the inspectors to function. Usually this consists of a combination of rehoming (for animals taken in by inspectors) and veterinary provision (to prevent some of the neglect which makes cruelty prosecutions necessary). They receive a yearly grant from the central RSPCA, currently about £20,000.

Branches are run by committees composed of unpaid RSPCA members who have been elected by other branch members at an Annual General Meeting. Committee members usually do a substantial amount of practical work keeping the branch going as well as coming together to make decisions about activities such as fundraising. They may employ some paid staff, especially if the branch has an animal home which needs full-time workers on the spot all day.

The Central RSPCA is governed by a Council of 25 unpaid trustees who meet together to decide policy directions and are responsible for decisions about employment of the most senior staff.

Collectively, the branches elect Regional Representatives to the Central RSPCA's governing Council. There are ten Regional Representatives, each elected by a group of branches.

The RSPCA membership as a whole elect the other 15 Council members by postal vote, with 5 council members retiring and standing for re-election each year.

What an enquiry might comment

The division between Council members elected by the whole membership and those elected by the branches introduces checks and balances which are probably useful because it means at least 10 of the 25 members are returned by people who know them personally and who are directly involved in the practical animal welfare work of the Society.

The RSPCA's membership is only a relatively small proportion of the individuals who make regular donations towards its work or regularly give practical support as a volunteer. It would strengthen the democratic structure if more of the the regular donors and volunteers became members and one option might be to explore with the Charity Commission whether the Society could be given permission to confer branch membership on regular branch volunteers to enable them to vote at the branch AGMs and stand as branch trustees.

Enquiry into the RSPCA?

Suppose there was to be an enquiry into the RSPCA, what would it find?

First of all it needs to be pointed out that the RSPCA is a charity, not a government body, so it's not exactly clear on what basis an enquiry would be set up: to paraphrase a famous saying of Thomas Erskine, one of our founders: "We can do what we decide with money we raised ourselves."

Provided the Charity Commission is satisfied that the Society is being properly run in the sense that the Trustees are not pocketing the funds or spending them on terrorism and the law on party political campaigns is not being broken there are no grounds for them opening an inquiry into the RSPCA on the basis of the normal regulation of charities.

It would be possible to have a parliamentary enquiry into the RSPCA to "look into" the way we work but (barring extraordinary changes to the way the law works) it couldn't (for example) order all the staff to work for the minimum wage or force the Society to take in all stray dogs.

It's hard to see how it would be possible to justify holding an enquiry into the influence of the RSPCA in our society without a complementary one into the influence of the Countryside Alliance and other animal-industry bodies.

An enquiry into the Tasmanian RSPCA by the Public Accounts Committee of the Tasmanian Parliament is currently in progress and if you follow the link you'll see that the terms of reference are: "the capacity of the RSPCA to receive and expend public monies in accordance with public expectations."

The vital difference between the Tasmanian RSPCA and the RSPCA in England and Wales is that we receive no direct state funding other than the usual charitable tax reliefs while the Tasmanian RSPCA inspectors are paid for by their government. The English government is getting a free service that the Tasmanian government pays quite a lot of money for.

Incidentally if our HQ was suddenly required to produce financial records for money spent on the inspectorate I have absolute confidence they could do it within a matter of hours.

Reading between the lines it looks as if RSPCA Tasmania's difficulties were partly because they were being paid for the inspectorate but not being given anything towards the costs of looking after animals seized in the course of investigations. So although they were being paid to provide an animal welfare enforcement service they were still subsidizing this from their own funds. It also looks as though they weren't spending enough money on administration (one of their kennel staff was keeping their accounts in her free time) so they couldn't easily produce exact figures for the amount spent on the inspectorate, kennels, legal fees etc. They seem to have been struggling to fund their shelter and some of the associated complaints (for example that their inspectors were reluctant to seize animals because they had no-where to put them) appear to relate to this.

As it looks as though the idea of a public enquiry into the RSPCA isn't going to go away I'm planning a series of entries on what the findings of an enquiry might be.

Just to put things in perspective, here is a chart showing prosecutions as a proportion of the work done by the RSPCA (using phone calls to the NCC as a baseline for the number of requests for help).

Is it right that a small clique of very influential people can jeopardise all the rescues of injured animals, provision of veterinary treatment and kind but firm help for people who cannot cope with the numbers of animals they have taken on?