Welsh Commercial Dog Breeders and their Waste

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.