Do you agree with the recommendation that anyone who transports livestock, poultry or horses should require transporter authorisation and a Certificate of Competence, including if they only transport animals on short journeys? Please provide any further relevant information.
It is the view of the Scottish Government that, in principle, animals should be provided with the same safeguards and protections during the shortest journeys as they are for other journeys. At the same time we consider that a proportionate and risk-based approach should be applied to the application of statutory regulation, and this includes considering carefully where the limits of statutory regulation lie.
We agree that there is merit in considering if all those who transport livestock, poultry or horses should require transporter authorisation and a Certificate of Competence, including if they only transport animals on short journeys. This should be considered alongside earlier proposals relating to the application of statutory regulation to non-commercial journeys as well as to commercial journeys.
Of the 329 responses to this question, 59.0% were in favour of requiring all transporters of livestock, poultry or horses to be authorised and in possession of a Certificate of Competence and transporter authorisation. 37.7% were not in favour and 3.3% did not express a view.
Those in favour of the proposal were relatively even split between a desire for all transporters to hold a Certificate of Competence only or both transporter authorisation and a Certificate of Competence.
Seven animal welfare organisations, and their supporters, considered that both transporter authorisation and a Certificate of Competence should be required for all journeys. They were joined in that consideration by a small number of respondents from the transport industry, livestock industry and farmers’ representative sectors. It was also suggested that training should be “mandatory and require refresher course every 1 to 2 years” (unnamed welfare organisation).
A number of these respondents also noted that this “needs to be risk-based and proportional” (Scottish Animal Health and Welfare Panel); whereas another respondent disagreed with that approach which they felt “could lead to the welfare of animals on short journeys being compromised” (Humane Society International UK).
Three animal welfare organisations, and their supporters, and representatives from the enforcement, transport, veterinary, farming and transport sectors considered a Certificate of Competence to be sufficient for all journeys. Respondents from these sectors also noted that drivers already undergo regular training and that many are also linked to assurance schemes e.g. Quality Meat Scotland and Red Tractor Livestock Transport Standards. Some farmers’ representatives advocated that “support should be made available to increase the opportunities of training and to cover the costs” (unnamed organisation).
A small number of respondents also suggested greater regulatory oversight of “the commercial transport of companion animals” (British Veterinary Association) and of “the commercial transport of cats and dogs” (unnamed organisation). A few organisations also questioned whether the intention was for Certificates of Competence to be required for owners using horse boxes; whereas a number of those involved in equestrianism considered such a requirement to not be “risk proportionate … for shorter journeys for horses for leisure or veterinary purposes” (Orkney Branch of the Pony Club).
Respondents from the Western and Northern Isles commented that journeys of under 65 km were the most frequent type on the islands and considered that authorisation and certification for such journeys would have a “disproportionate impact on crofters and small scale farmers” (Scottish Islands Federation). It was also noted that “they must continue to comply with the technical rules on fitness to travel, means of transport and transport practices” (Comhairle nan Eilean Siar).
A number of organisations and individual respondents also considered that on-farm journeys, which may include movements to spring pastures, should be exempt from the proposed requirements.