Ms Sarah Lynch:

I thank the committee for inviting Dogs Trust to speak to it today and we welcome the joint committee’s commitment to gathering information on important dog welfare issues. I am policy manager at Dogs Trust and I am joined by my colleague, Conor Brennan. On behalf of Dogs Trust, we welcome the opportunity to assist the committee in discussing how we can work together to address the matters presented here today. Our presentation will focus on microchipping and dog breeding establishments, with an overarching aim to explore collaborative solutions that advance dog welfare in Ireland.

Dogs Trust has been working in Ireland since 2005. Our mission is to bring an end to the destruction of stray and abandoned dogs through a national responsible dog ownership campaign and an education programme. In 2009, we opened the doors of our rehoming centre in Finglas, Dublin and today Dogs Trust rehomes dogs all around the country through both our rehoming centre and our regional rehoming programme. Last year, we rehomed 862 dogs and to date we have rehomed more than 20,000 dogs.

Since as far back as 2009, six years before the commencement of the Microchipping of Dogs Regulations 2015, Dogs Trust has not only seen the value of the microchip but the power of the data that are recorded against it. In that time, we have chipped almost 21,000 dogs in our care. Outside of our rehoming centre, we ran national awareness campaigns, starting in 2013, pushing the message out to the public on the importance of microchipping, updating contact details recorded against the chip, and ensuring all dog owners are aware they must be in possession of their microchipping certificate. Through our various microchipping schemes, we have assisted almost 29,500 dog owners to become compliant with the microchipping of dogs regulations. That has been accomplished through the hosting of microchipping clinics, delivering microchips to dog owners most in need of our help via a dedicated network of vets throughout the country, and allowing dog owners to update or change the contact details registered against their dog’s microchip free of charge during our national chipping week.

We were encouraged to hear the Department supply figures to this committee last week to the effect that 600,000 dogs have been chipped in the Republic of Ireland since 2017. Building on this positive work, Dogs Trust Ireland believes now is the opportune moment to modernise the legislative framework to keep pace with other regulations and current trends in dog ownership. We believe traceability is key and high-quality data are the means to produce meaningful traceability. Therefore, greater emphasis must be placed on the quality of the input data as we have found that individual databases have different standards in terms of the quality of the input. Greater obligations on database providers are needed with regard to all relevant details, including date of birth, breed, colour, markings, gender and owner contact details. Widespread anecdotal evidence reveals that such details are currently not being kept to a requisite standard. Greater emphasis should also be placed on the guidelines in place for databases and for collecting certified data. With the update of the microchipping regulations, there is an opportunity to issue clear and mandatory requirements on registered databases operating in Ireland to ensure the highest quality data are held.

That is why we believe a central place for hosting data is an obvious next step for the advancement of dog welfare. Ideally, a central database should be kept up to date, with a process implemented for the removal of deceased dogs. It should provide one point of call for dog owners to update their details easily. We recognise the difficulty in creating a single database as each database is run as a commercial enterprise. If this is not possible, there should be a single repository for searching information.

We believe all data should be held in an accessible and digital format by database providers. For example, some databases require the scanner of the dog to phone them to get the owner information, which delays reunification. Having an accessible, unified location of the relevant data would bypass this issue as they could be obtained online. In this way, all databases could be regularly shared with a central repository that cross-checks this information against similar databases operating in Ireland, for example, dog breeding establishment, DBE, licence holders; sellers and suppliers; and registered owners, trainers or breeders operating in the greyhound racing industry.

The importance of cross-checking the microchipping number against an owner that may hold a DBE licence or a seller and supplier registration number cannot be understated. A simple change to introduce a mandatory field when registering or updating a microchip will open the door to full transparency for enforcement officials and registered rehoming charities.

We advocate for a streamlined central system for updating details that is easy to understand, not overly burdensome on the owner and, crucially, affordable to all dog owners. Revised microchipping of dogs regulations should strengthen powers of authorised officials to fine owners where there are incidents of false information knowingly being submitted to the database or where there is widespread non-compliance. Alongside this, a Government campaign could be run to increase owners' awareness of their obligations with regard to keeping their dogs' microchip details up to date. This should, crucially, run in tandem with any engagement with database providers and registered breeders and sellers.

Technology is available to integrate the databases. The central repository would need to be independent to address concerns regarding access to information. This will lead to greater enforcement of responsible dog ownership and correct dog welfare practices. On a much wider scale, compliance with the Dog Breeding Establishments Act and correct information displayed as part of the requirements under the rules on the sale, supply and advertising of pet animals are two clear examples.

We are encouraged that work is continuing behind the scenes with the Minister for Agriculture, Food and the Marine and departmental officials to discuss options as to how best to tackle the issue of microchipping which, as far as we are concerned, can unlock solutions and enforcement for many welfare issues, including ear cropping.

As I realise the subsequent committee session will cover the Dog Breeding Establishments Act, I will outline Dogs Trust's hopes for the future review and implementation of the Act. Following the introduction of voluntary guidelines in 2018 to supplement the Act, the then Minister of State, Deputy Canney, promised the Act would be updated. This commitment was reiterated in the present programme for Government. Close to three years on, we believe now is the ideal time to prioritise this important legislation and ensure the right structures are put in place.

Following engagement with Department of Rural and Community Development officials on the revised text of the Act, we believe three key changes to the Act will have a lasting impact on dog welfare in Ireland: a sufficient staff-to-dog ratio; greater transparency and accessibility of the DBE licence register; and the 2018 guidelines being placed on a statutory footing.

On sufficient staff-to-dog ratio, owing to the significant variation in workload between breeds and numbers of litters, Dogs Trust understands it is difficult to set a minimum ratio. However, it is unreasonable and impractical to suggest that one staff member could properly manage 25 breeding bitches. The current guidelines for DBEs states “it is recommended that this will be equivalent to one fulltime equivalent per 25 breeding bitches”. In practical terms, workers must fulfil a thorough sanitisation programme for each of the 25 dogs as well as the number of puppies born to them, which could result in as many as 150 dogs under the care of one staff member during full-time working hours.

The staff-to-dog ratio must be sufficient to provide the level of care set out in the DBE Act and, although establishing the number of staff requires internal assessment, we do not foresee any circumstance where a non-human supervisor can come close to meeting these requirements even under the guidelines. Indeed, the adoption of widespread mechanisation to fulfil socialising needs is cruel and deprives a companion animal of necessary human interaction.

I turn to greater transparency and accessibility of the DBE licence register.

The review of the Dog Breeding Establishments Act affords an opportune moment to empower the public with the knowledge of the environment a puppy or dog has been bred within before buying from a licensed DBE. The current Act allows for a local authority to maintain a register of DBEs as it sees fit. In practice, however, this has led to only approximately 50% of local authorities making the register available for members of the public to view online. Instances of the register being kept up-to-date and what information is shared, in what format, is entirely uneven as well. Empowering the public by mandating for the register of all DBEs to be made accessible online via each local authority portal and updated on an ongoing basis would allow for the traceability that should be available upon purchasing a dog from a DBE. It would also facilitate the seamless creation of a centralised register where interested parties can easily access the key information for each DBE licence holder.

Regarding the guidelines, we are also eager to explore how the 2018 guidelines for DBEs will interact with any new revision of the Act. We believe this is a great basis for strengthening the Act and should be recognised in primary legislation. We recognise that the effective implementation of the guidelines cannot satisfy a one-size-fits-all approach. The care required for a pack of hounds is very different to that for lapdogs. The option of introducing separate guidelines or regulations for different types of establishments that come under the definition of a DBE, such as boarding kennels, rescues or hunt kennels, would be welcome and we are happy to work with the Department to explore this approach in a way that satisfies the wording of primary legislation.

Overall, any legislative changes should be looked at in the round. Attention should be placed on how the updated regulations complement the Dog Breeding Establishments Act, the Control of Dogs Act and the Animal Health and Welfare Act, and we look forward to listening to the officials from the Department of Agriculture, Food and the Marine and from the Department of Rural and Community Development in this regard. Some progress has been made in these policy areas but there is a worry that the impetus in recent years is waning and progress in key legislative pieces has stalled. We believe that by maintaining the partnership between welfare groups and Government we can continue to drive effective change that leaves a lasting legacy and puts Ireland at the forefront of dog welfare in Europe. I thank the committee for its time and I welcome any questions that committee members might have.