Suggestions of Animal Friends for Alterations and Amendments to the Proposal of the Animal Protection Act
We suggest the introduction of an Article 4, item 2, sub item 23, with the following wording:
(2) It is prohibited to:
23. Raise animals for purposes of fur production
We suggest a transitory period of five years, which means that the transitional and final regulations, as well as penalty regulations, should be amended in this period.
Regulation on the prohibition of raising animals for purposes of fur production was included in the working version of the Proposal for the Animal Protection Act.
Explanation is attached as a separate document entitled 'Reasons for Necessity of Banning of Breeding Animals for Fur in Croatia'.
This regulation is included in the Austrian law, which served as the basis for this proposal.
We suggest the introduction of an Article 48, item 8, with the following wording:
(8) It is prohibited to keep dogs on chain or tied otherwise permanently, except if they are tied by a prolonged wire leash that guarantees a maximum of movement and if it is done exclusively for their own protection, protection of other animals, or protection of people.
Regulation on the prohibition of keeping dogs on a chain was included in the working version of the Proposal for the Animal Protection Act.
Chained dogs are not sufficiently protected by Article 4 and other articles that refer to the welfare of companion animals. Even though it is well known that chained dogs suffer physical pain and are likely to develop mental disturbances, possibly including aggressive behavior, in practice veterinary inspectors cannot prohibit the chaining of dogs if the Act does not regulate that.
In the Austrian law, on which this proposal for the Animal Protection Act was based, keeping dogs on chain is completely forbidden.
Article 57, item 4 of the Proposal for the Animal Protection Act states the following:
(4) An animal from the animal shelter that is not returned to its owner and cannot be further kept or given for adoption may be put to death after 30 days.
We suggest that Article 57, item 4 should be abolished in its entirety or that the period before the animal is put to death should be prolonged to the minimum of 6 months, which was also included in the working version for the Proposal of the Animal Protection Act.
Animal shelters should offer a secure refuge to abandoned animals until they are adopted. The period of 30 days, after which animals in animal shelters can be put to death, abolishes the very purpose of such shelters and impedes organized adoption of animals, especially in summer months, when the adoption possibilities are scarce. Abandoned animals should not be punished by death for the negligence of their former owners, which is also the opinion of Croatian citizens, who object to have their money spent on killing abandoned animals in animal shelters that are financed with their money.
Austrian law on which this Proposal for the Animal Protection Act is based lacks such regulation.
Article 4, item 2, subitem 8 states the following:
(2) It is prohibited to:
8. Organize dog races on hard surfaces.
We suggest that Article 4, item 2, subitem 8 should have the following wording:
(2) It is prohibited to:
8. Organize dog races.
Regulation on the prohibition of organizing dog races on any kind of surface was included in the working version for the Proposal of the Animal Protection Act.
Dog races are equally cruel on all surfaces and the Act should not promote dog races on soft surfaces, which it indirectly does through this formulation. Dogs that are meant to serve as race dogs are usually kept in cages and only rarely live longer than 4 or 5 years, since they suffer from wounds and illnesses caused by the manner of their breeding, race preparations, transport, and races as such.
In the USA, where the problem of dog races is extremely acute, 34 states have legally prohibited dog races on all surfaces.
Article 32, item 2 states the following:
(2) Surgical interventions on animals during experiments, as well as in the production of biological preparations, can be performed by veterinarians, medical doctors, pharmaceutical experts, medical biochemists, and dentists/agronomists specialized in animal breeding, as well as biologists if they have passed the exam from item 1 of this Article.
We suggest that Article 32, item 2 should have the following wording:
(2) Surgical interventions on animals during experiments, as well as in the production of biological preparations, can be performed by veterinarians and medical doctors/surgeons if they have passed the exam from item 1 of this Article.
Regulation on performing surgical interventions on animals exclusively by veterinarians and medical doctors was included in the working version for the Proposal of the Animal Protection Act.
It is impermissible that surgical interventions on animals during experiments should be performed by individuals with no expertise in surgery. In our opinion, surgical interventions on animals should be performed exclusively by veterinarians or possibly by medical doctors specialized in surgery. Currently it is also allowed to general practitioners and medical doctors with other specializations, pharmaceutical experts, agronomists specialized in animal breeding, medical biochemists, dentists, and biologists, which we consider unjustifiable.
Article 2, items 4 and 5 state the following:
(4) This Act should not be applied in the management of hunting preserves and game, which excludes:
1. Breeding and keeping animals used for assistance in hunting;
2. Breeding and keeping animals for hunting purposes outside of the hunting preserve.
(5) This Act does not apply to fishing.
We suggest that Items 4 and 5 should be deleted from Article 2.
Such regulations in the Animal Protection Act exclude a large number of animals, which remain unprotected although their exploitation may be regulated by other laws or minor acts. We are of the opinion that the Animal Protection Act does not interfere with other laws, which is corroborated by the fact that the current Animal Welfare Act has no such regulations; therefore, we consider them obsolete and detrimental to the active protection of animals in the Republic of Croatia.