Welsh Commercial
Dog Breeders and their Waste
Many licensed dog
breeders in Wales are acting illegally when disposing of solid waste from their
dog breeding kennels such as faecal matter, contaminated soiled bedding, and
empty chemical containers. These items
must all be disposed of via a suitably permitted facility. Dog faeces and carcasses are defined as
'hazardous waste' under Hazardous Waste Regulations 2005 and it is the
responsibility of the dog breeder to ensure that the site used for disposal is
permitted to receive this particular type of waste (Waste Code 18 02 02*).
However, Puppy
Alert can reveal that Councils in Wales are licensing dog breeders with full
knowledge (FOI) that they are not following current legislation, they are using
the following illegal means of hazardous waste disposal: slurry pits, dung
heaps, septic tanks, farm waste, compost, council bins, fields, skips, burning
and incinerators (the latter requires a licence).
It has for many years
been common practice for livestock and sheep farmers to use a slurry pit for
the purpose of storing the slurry from the farm, when the time is right,
according to legislation, spreading it on the land is considered acceptable.
However whilst the
spreading of livestock farm waste (slurry) is acceptable the storing and
spreading of dog faeces is not. This is of
grave concern as many licensed dog breeders in Wales are also working farms
with many Welsh farmers having diversified into dog breeding. Some owning and
breeding from 50 to 200 breeding bitches, most keeping their dogs in
agriculture sheds. Many farmers have continued the practice of using the slurry
pit for the storing of dog faeces together with farm waste then using it as a
fertilizer and spreading it on the land. This both unacceptable and illegal. Even worse considering that sheep and
livestock are grazing on the grass ending up in the food chain.
The Centers for
Disease Control in the USA strongly warns against the use of large quantities
of dog faeces as a fertilizer. Common
pathogens such as Campylobacter bacteria and parasite worms can infect humans,
composting and sunlight are not reliable as far as destroying these viruses
which can 'aerosolize' (float in the
air) and attach to the leaves of edible plants fruit and vegetables.
The open burning of
controlled waste and land spreading of dog faeces and (stillborn) carcasses is
also an offence under the Environmental Protection Act 1990. It is very unlikely that the Environment
Agency would give permission for wastes such as this to be composted. The holder would need to apply for a
permit/waste exemption and this would certainly be refused.
The advice from the
Environment Agency for kennels is as follows: wash down from kennels and
drainage should be directed to the foul sewer, or if it is not available to a
sealed cesspool. These areas should be
covered to prevent rainwater being collected.
The contents of the cesspool should be removed by a licensed contractor
for off-site disposal.
Drainage to a
private sewage treatment plant must only be considered as a last option, and
only if appropriate treatment and flow balancing are provided. The plant would need routine maintenance to
be carried out under contract with the supplier (specialist knowledge is
required to ensure correct operation to meet consent conditions). Because the high strength of the effluent may
affect the adequacy of the treatment, advice should be sought on the design,
installation and operation of this type of plant.
With this advice
available from the Environment Agency for kennels, why have Councils not advised
dog breeders when granting and renewing their dog breeding licenses of their
responsibilities, instead of allowing so many to operate illegally?
There are
approximately 162 licensed dog breeding kennels in just three counties in
Wales, Carmarthenshire, Ceredigion and Pembrokeshire, Wales, with at least 5,200
breeding bitches capable of producing at least 25,000 puppies per annum, without
taking into account the 249 premises that are operating unlicensed. These figures represent a large numbers of
dogs and their waste. It is unacceptable that these Councils and the Welsh
Assembly, whilst looking at dog breeding under CAWES, did not appear to be
aware of this illegal activity as it has not been raised. Puppy Alert hopes by highlighting the
situation that action will be taken by the Environment Agency against Councils
and licensed dog breeders that are flaunting the law and placing humans and
animals at risk by contamination of the land and ultimately the livestock
entering the food chain.
Update: 10.02.2013
It has taken the
Welsh Assembly until now, when alerted by concerned members of the public, (even
though this situation has been in operation for years) to wake up to the situation
amongst their farming community that are involved in dog breeding alongside
farming. The Councils licence and inspect premises for dog breeding they have a responsibility to ensure that all dog breeder dispose of their dog waste according to current legislation and not in ways that are irresponsible, unacceptable and illegal.
Here is their response to my email.
Please read as follows:-.
Thank you for your letter about the disposal
of waste at licensed dog breeding
establishments. It has been passed to me to
respond.
The disposal of waste is not a Welsh
Government matter; the enforcement responsibility lies
with the relevant Local Authority and also
the Environment Agency. However, the Guidance
accompanying the forthcoming Animal Welfare
(Breeding of Dogs) (Wales) Regulations
2013 does cover waste and stipulates the
following:
“Facilities should be provided for the proper reception, storage and
disposal of waste.
Particular care should be taken to segregate waste arising from the
treatment and handling
of dogs with infectious diseases. The licensee should check with the
Environment Agency
for current guidance on the appropriate means of disposal”.
The aforementioned Regulations are currently
being translated and checked by the Welsh
Government’s Legal Department. Once this
process has been completed, they will be
tabled in the National Assembly for Wales for
a period of 40 days to allow Assembly
Members to comment on its content. Finally, a
Plenary Debate will be taking place on 7th
May 2013. If there are no amendments, the
Regulations will come into force shortly after
this process.
