SUPPLEMENTARY SUBMISSION FROM THE SCOTTISH KENNEL CLUB
Tail Docking: Scientific Research
The Kennel Club regrets that the Government’s proposals to ban tail docking
with certain limited exemptions effectively dismiss the evidence presented by
scientists from across the globe that tail docking performed on puppies does
not cause pain. A number of studies conclude that tail docking is not harmful
to puppies for various reasons:
1. Professor Grandjean of the Veterinary School of Allor, (France), is the main
author and scientific co-ordinator of the ‘Royal Canine Dog Encyclopaedia,
(2000)’. He identified the neonatal period that began at birth as the 'vegetative
phase' and concluded that at this stage of development puppies had few
reflex activities because their nervous system was not developed. He
explained this was why some major surgical operations could be performed
without anaesthesia during this time - as myelination occurred from the
anterior to the posterior of the dog, perception of pain was the last sense to
appear in neurological development.
2. Professor Hales, a retired biomedical Research Professor at the Faculty of
Medicine at Charles Sturt University (Australia), Visiting Professor at the
Faculty of Veterinary Science at the University of Sydney and Chief Research
Scientist at the Division of Animal Physiology/Production at the
Commonwealth Scientific Industrial Research Organisation, examined the
scientific research published in international journals and subsequently tested
reflexes in neonatal puppies. He found there to be only one scientific study of
tail docking in puppies and concluded that while it purported to show the
procedure to be painful, the study was scientifically flawed by omitting control
pups. He also claimed it was invalid to compare humans or lambs with
puppies and that studies of newborn rats, which could more validly be
compared with puppies, showed that neuro-physiological pain mechanisms
were not effectively functional until around 11 days old. Supporting Professor
Grandjean’s argument concerning reflexes, Hales too observed that in
neonatal puppies, the characteristic hind paw scratching in response to
tickling mid-side skin, was initially absent, faintly present in most puppies at
day 8 and that puppies did not exhibit adult-like characteristics until at least
These arguments are also supported by:
3. Professor Rudolf Fritsch, the Head of the Clinic of Veterinary Surgery at
Justus-Liebig University, (Germany). He concluded that there were two
distinct groups of newborn animals, the "Nestfluchter", and the "Nesthockern”.
The "Nestfluchter" (or precocial), which included human babies, lambs and
calves were more mature at birth as the nervous system was fully developed
just after the moment of birth. However the "Nesthockern" (or altricial), which
included puppies, kittens, rats and others was relatively immature at birth - up
to around two weeks of age, they could not hear or see, use their hind legs,
urinate or defecate without their mothers' stimulation. Fritsch went on to claim
the animals in the Nesthockern group were born relatively immature, completely naked, blind, deaf, immobile and very helpless, as their nervous
system at birth was not fully developed. He also concluded that there were
still cell divisions in the brain and some nervous threads not fully developed -
in psychological tests, the time between the nervous impulse and reaction
(chronaxie) took 3-4 times longer than it did in an adult.
4. Similarly, in 1941, Volkhov determined that animals, at this period of life,
had very little feeling of pain. He claimed the conscious feeling of pain was not
likely at that age.
5. Schmidker also wrote in his doctorate in 1951 about the feeling of
pain in new-born puppies. He concluded: "Incomplete development of
the nervous system at the time of birth and the very high chronaxie
value in connection with the fact that the animal is not able to react
effectively to pain, gives us every reason to believe that the actual
feeling of pain is very low in the new-born of this group of mammals
(dogs). In other words, at this age and biological condition, it would
have no absolute meaning to talk about pain".
Fritsch's argument counters that put forward by Jean Hofve, DVM at the
Animal Protection Institute, who pointed out that it was well documented in the
human medical literature that newborn humans felt pain and neonatal pain
management was taken seriously. She pointed to one report from the
Department of Paediatrics at the Washington University School of Medicine,
that: "Clinicians believe that infants can experience pain much like adults, that
[hospitalised] infants are exposed daily to painful procedures, and that pain
protection should be provided, even very prematurely born infants respond to
pain." Fritsch did not deny this claim and his argument does not contradict
these findings. However his research, widely supported by other scientists,
went further and undermined Hofve’s argument by concluding that puppies
were in a different neonatal group to humans. It is absolutely certain that the
docking of tails on small lambs and pigs and also the castration of young pigs,
goats and calves during their first days of life, would cause considerable pain
if done without an anaesthetic. However, from the point of view of the docking
of dogs, whose nervous system is not fully developed during the first few days
of life, this would not be the case.
Other opponents of tail docking are not averse to misrepresenting information.
For example in October 2002 the Animal Welfare Veterinary Division at Defra,
prepared a substantial report to assist in decisions by UK authorities. It
included the critically important statement: "...and whilst animals may show
different signs of pain it is clear they do feel pain in the same way as man,
and the pain threshold has been determined to be the same in both dog and
man (Fleeman, 1995)." The threshold for pain was such an important point
that Professor Hales contacted Dr Fleeman to discuss and clarify her position,
only to find that she had never researched this topic at all. She had simply
discussed pain management at an in-house seminar in the University of
Melbourne Veterinary Clinic and was surprised and troubled to find she was
having scientific findings wrongly attributed to her.
Therefore the Kennel Club advocates that prior to making docking illegal as
part of the Animal Welfare Bill, Defra further examines research that has been
produced by various scientists. Since the most substantial and conclusive
research proves tail docking is not harmful to puppies, the Kennel Club is of
the view that amending current legislation is unnecessary and that breeders of
traditionally docked breeds should be able to exercise choice over whether to
dock their dogs’ tails in conjunction with their veterinary surgeon, especially
since Kennel Club breed standards have been amended so that traditionally
docked breeds now include clauses that provide a description of the tail for
undocked dogs, ensuring that either may be shown.
Regulatory Impact Assessment on Mutilations Regulation
For over a decade the Kennel Club has been receiving feedback from
breeders involved with docked breeds stating that should docking be
proscribed by Government, then they will stop breeding dogs altogether.
Experience in countries such as Sweden1 and the Netherlands has shown
that this is likely to be the case.
The financial impact this would have on industry, breeders and dog owners is
Industry (The Kennel Club): The Kennel Club registered 77,695 dogs of
traditionally docked breeds in 2004, which represented approximately 30% of
registrations at a value of £3,088,548 and transfers at a value of £1,544,274
to the Kennel Club. This is a significant percentage of our annual income -
amounting to £932,340 worth of registrations and £466,170 worth of transfers
to new owners, totalling £1,398,5102.
These figures are based on the assumption that all breeders of traditionally
docked breeds will stop breeding puppies if docking becomes illegal. While
this is an unlikely assumption, it is impossible to estimate exactly what
percentage of breeders will continue to breed traditionally docked dogs.
However, breeder and breeding club correspondence with the Kennel Club
suggests that if a ban on tail docking were enforced (even with an exemption
for working dogs), many breeders would stop breeding traditionally docked
breeds, which would result in income from registrations falling dramatically.
Breeders: Breeders sell approximately 70% of puppies at an average of over
£450 per puppy. If a ban were to be enforced, this would collectively cost the
breeders who sell puppies approximately £44,000,000. If as a result of the
ban, a dog that a breeder kept injured its undocked tail, this would also have a
financial impact on the breeder in terms of veterinary bills (see below).
According to a report from the Council of Docked Breeds conducted in 1992, entitled ‘Tail Injuries of Shorthaired German Pointer Dogs Born in Sweden in 1989’, tail injuries increased from the 1 January 1989 when the docking of tails in Sweden was banned. This conclusion was based on the Swedish German Pointer Club’s investigation into how common and how serious a problem tail injuries were in the long-tailed German Pointers. As part of the investigation, the Club asked the breeders: how many dogs in a litter received tail injuries; the type and seriousness of the possible tail injury, possible tail amputations and the “degree of strain in terrain” that the dogs had been put through. The investigation concluded that after
the 1st January 1989 German Pointers (27%) received a fair amount of injuries on their long tails, even before they had reached one year of age, that their tail injuries continued to occur during 1990-1 and the frequency and severity of tail injuries increased (35% had suffered tail injuries by the time they were 2.5 years old). The types of tail injuries included: wounded and bleeding tips, swollen, or broken tails.
2 Figures are based on the cost of basic registration, which is currently £12 per puppy and transfer charges at a cost of £10 per puppy, when on average 60% of registrations are transferred.
Sellers: Pet shops also sell puppies at an average cost of £450-£500 per
puppy after having bought them mainly from dealers or puppy farms at a cost
of £150-£200. There are around 3000 pet shops and around 10% (300) of
these sell puppies, 30% of which are of traditionally docked breeds (based on
registration statistics). Therefore pet shops could potentially loose a minimum
of £27,000 in puppy sales3.
The Kennel Club would at this stage reiterate its concern to Defra that there is
no clause in the Draft Animal Welfare Bill to abolish the practice of selling
puppies in pet shops. The Kennel Club remains concerned that puppies may
be removed from their mothers before being fully weaned and transported to
pet shops. The journey and the alien environment at which puppies arrive, is
stressful for them and as a result puppies may develop physical and
psychological problems. In the absence of introducing a ban on the sale of
puppies from pet shops, the Kennel Club would like to see a provision
introduced in the Bill to make it obligatory for notices to be displayed in
shops/stalls outlining the age restrictions on purchasing a pet and for
information leaflets to be provided at the point of sale. The Kennel Club’s
Accredited Breeder Scheme requires members to provide written information
to new owners on the care of puppies.
Dog owners: It is difficult to estimate what financial impact a ban on tail
docking would have on a dog owner: for some dog owners the ban will have
no financial impact; for some dog owners the price of their favourite breed of
dog may increase as they become rarer; and for many dog owners a ban on
docking would have a financial impact in terms of veterinary bills if their dog
injured its undocked tail.
One dog owner contacted the Council of Docked Breeds to give an example
of how much a ban on docking could cost dog owners if their dog injured its
The cost of treating one dog’s tail problems were as follows:
12 May 2000 – initial consultation and antibiotics £35.37
16 May 2000 – surgery to remove 4 inches and medication £128.85
16 May 2000 & July 2000 – consultations, dressings and medication £171.04
17 July 2000 – surgery to remove remainder of tail and medication £247.38
Cost estimates are based on every pet shop selling just one puppy of a traditionally docked breed. In reality, each pet shop sells many docked puppies so this figure would be considerably higher. Such losses to pet shops would be incurred if they were no longer able to purchase puppies of traditionally docked breeds, or if they could purchase, but not sell these puppies. It is quite common that once injured, efforts to retain part of the tail fail and total amputation results in due course.
Memorandum submitted to the Environment, Food and Rural Affairs Select
Committee from Dr Peter Shaw in August 2004 also states that: “A damaged
wagging tail can produce havoc by throwing blood about through centrifugal
action and it is difficult to bandage. In general a dog will bite at a damaged
tail, especially if bandaged, so that treatment also involves the use of large
conical head collars or muzzles to prevent this…In the worst cases tail
amputation is necessary, and dogs then need to wear collars for up to six
weeks during which the owner has to stay with dogs when they are fed (with
muzzle or collar off). The cost of such an accident can run into several
hundreds of pounds”.
Studies that conclude tail injuries not to be uncommon clarify that some dog owners will inevitably face higher veterinary bills if a ban on docking is enforced:
• In 2002 the Metropolitan Police Dog Training School provided the Kennel
Club with statistics on how many dogs had to be docked over two years
because of tail injuries. The veterinary surgeon who carried out the
amputations reported that in 2001, 4 undocked dogs needed to have a full
amputation and 1 partially amputated tail needed full amputation. Between
January and May 2002, 4 undocked dogs needed to have a full
• A statistical summary produced by the Kennel Club reinforced the premise
that the majority of working gundogs were docked, as over 98% of the 763
working gundogs surveyed were docked. However the survey still showed
that of the small percentage of those undocked, a high proportion suffered
tail damage – with 75% of Clumber Spaniels, 20% of English Springer
Spaniels and 25% of Wirehaired Vizsla’s all suffering damage. The
Kennel Club does not agree with the Government’s current position that
tail docking should be banned, even if working dogs would be exempt from
this ban. The Kennel Club believes legislation to this effect is unnecessary
considering it allows customarily docked breeds to be shown with or
without their tails, and the Kennel Club Breed Standards reflect this. For
the past five years the Kennel Club Breed Standards and Stud Book
Committee has liased closely with individual Breed Clubs and Councils in
order to amend the Breed Standards by adding a full tail clause for those
breeds which are customarily docked.
The veterinary surgeon who carried out the amputations is Miss J Dennis of the Laurels Veterinary Centre, I Homefield Road, Bromley, Kent, BR1 3AW, 0208460 2033. Miss Dennis is happy to be contacted in respect of authenticating the data if necessary. The summary was based on responses to a questionnaire sent to 331 secretaries of 167 Kennel Club registered Field Trial and Gundog Clubs of which 95 ran events for Spaniels and the Hunt, Point and Retrieve Breeds, and 500 Field Trial judges of which 149 judged Spaniels and 40 the Hunt, Point and Retrieve Breeds. The Clubs and Judges involved with Retriever and Pointers and Setters were included in the survey as many of their members also owned traditionally docked gundog breeds.
Would you anticipate that demand for docked dogs would decline, or would you anticipate an import market developing?
While it is difficult for the Kennel Club to estimate market changes, Quentin L.
LaHam Ph.D, Titular Professor, (retired) claimed “In my view this law will so
negatively affect the breeds concerned, as to effectively eliminate them from
international competition and could bring about great hardship upon individual
dogs…Certainly, those breeds concerned stand a serious chance of going
into decline and international exchange will have an influence on the export of
Dew Claw Removal:
Correspondence to the Kennel Club from breeders and breed clubs suggests
that should Defra make it illegal for lay people to remove dew claws of new
born puppies, breeders will simply sell dogs without removing their dewclaws.
While it costs around £6.50 - £8 per puppy for a vet to remove its dewclaws
within 2 or 3 days of birth (depending on its size, temperament etc), a
dewclaw removal operation on a developed dog can be extremely expensive
in later life. Unfortunately, dewclaws are easily damaged so owners of dogs
with dewclaws are likely to incur steep veterinary bills for the removal of at
least one dewclaw at some point during the dog’s life.
The financial impact that a ban on lay people removing dewclaws would have
on breeders and dog owners is as follows:
Breeders: Dewclaw removal is most often performed in puppies at 2 to 5
days of age. While in some instances, local anaesthetic may be used at this
age; general anaesthesia is not used. As breeders sell 70% of puppies, they
are unlikely to have a vet remove the dewclaws of puppies they sell as this
collectively this would cost breeders alone between £1,171,074 – £1,549,421
per year7. Veterinary fees for removing dewclaws are high considering the
procedure is so simple that many breeders are experts at doing this
themselves. This is because at 2-5 days of age, bones that make up the
dewclaw are so tiny and soft that cutting them off is easy. However selling
puppies without dewclaws is likely to impose additional costs on their new
Dog owners: When older animals need their dewclaws removed, (as may
happen if their dewclaws are not removed as puppies), sedation or general
Figures are based on breeders not removing the dewclaws of 70% of puppies registered with the Kennel Club in 2004.
“The dewclaws, if not kept cut short, can grow around and grow right into the side of the foot or foot pad, which is a very painful and needless thing. Also, dewclaws can and do get hooked on everything, even carpet, and if they tear it is very painful and can bleed profusely and be very traumatic for both dog and owner. It is much better to prevent such problems with dewclaw removal, and this quick procedure is more readily accepted and even encouraged” http://miniatureschnauzer.ca/breedinfo.htm#dewclaw anaesthesia is necessary. General anaesthesia induces unconsciousness, complete control of pain and muscle relaxation. If general anaesthesia is used, the pet receives a pre-anaesthetic sedative-analgesic drug to help it relax, a brief intravenous anaesthetic to allow placement of a breathing tube in the windpipe, and subsequently inhalation (gas) anaesthesia in oxygen during
the actual surgery. This procedure is obviously much more expensive to
perform on a fully-grown dog than a puppy. Recovery time is also longer and
many adult animals will bother the incision excessively because it is so easy
to reach. This usually necessitates the placement of an Elizabethan collar, a
funnel shaped plastic device that surrounds the animal's head, so that it
cannot lick or chew the sutures. This is necessary but distressing for the
The cost of removing a fully developed dog’s dewclaws is difficult to estimate
because it depends on the size of the dog, the dog’s temperament, how many
dewclaws need removing at once, and the veterinary surgeon. The operation
can cost up to £600, and then up to £50-£60 per claw thereafter, providing
they are removed at the same time.
After ringing round numerous vets, the Kennel Club and breeders found that there was great disparity in the amount vets charged for removing the dew claws of fully developed dogs. Quotes for dewclaw removal (including anaesthetic and surgery) ranged from between £150-£600.