Part 4 - DEFRA's Regulations
Part A – General conditions (Schedule 2 of the Regulations)
1.0 Licence display
1.1 A copy of the licence must be clearly and prominently displayed on any premises used for the licensable activity. The licensed premises address must be displayed on the licence. It must be displayed in a public-facing area of the premises such as the entrance. 1.2 The name of the licence holder followed by the number of the licence holder’s licence must be clearly and prominently displayed on any website used in respect of the licensable activity.
- No customer and no one working in this sector has ever asked for a restaurant rating system, and one that’s incomprehensible and unworkable is worthless.
- No one’s ever asked if we were licensed and if people knew we were licensed or inspected by a local authority it would hold less weight than a fake google review.
2.0 Records
2.1 The licence holder must ensure that at any time all the records that the licence holder is required to keep as a condition of the licence are available for inspection by an inspector in a visible and legible form or, where any such records are stored in electronic form, in a form from which they can readily be produced in a visible and legible form.
2.2 The licence holder must keep all such records for at least 3 years beginning with the date on which the record was created.Electronic records must be backed up.
Universality again, trying to shoehorn paper and electronic records into the same box.
With a paper system it’s imperative to remove dead cats, people who move out of the area or people who use you once because their normal cattery is full otherwise the system is unwieldy.
Only records for boarders at the time of inspection are relevant. It’s our business and we’ll decide when to discard records, whether to keep records forever delete them from the cloud or burn them every bonfire night.
3.0 Use, number and type of animal
3.1 No animals or types of animal other than those animals and types of animal specified in the licence may be used in relation to the relevant licensable activity.
The licence applies only to boarding cats. If you are concerned about the welfare of other animals, you should inform the relevant person in the local authority, the police or a suitable animal welfare organisation.
3.2 The number of animals kept on any premises at any time must not exceed the maximum that is reasonable taking into account the facilities and staffing.
The licence must clearly state the maximum number of cats that are allowed on the premises. >Undeclared numbers are a breach of the licence, especially if staffing levels are not increased.
You should take into account any other cats that are on the premises (such as pets) and the impact on facilities and staffing. If a cat is located in a different part of the facility, it wouldn’t necessarily need to be included in the figure for the licence.
Reality check: Clockwork doesn't exist in our sector
Ryan Air, road & train delays have more of an impact on exceeding any licensing numbers than anything else and there’s nothing in any of DEFRA’s regulations that can foresee flight cancellations or travel delays.
On yet another practical level, if you’re licensed for 20 cats and 20 cats are in, you don’t have a spare room to exceed that number and no one is going to train someone for a few months just to do a day’s work to satisfy DEFRA and then be laid off again as soon as the maximum number is reached again.
4.0 Staffing
This entire section is not worth the pixels space to include anything but the rebuttal.
It’s none of DEFRA’s business who we employ.
- DEFRA don’t dictate how many cows a farmer can safely milk or how many collies a herd of sheep requires to move fields because there are multiple variables - and dictating staff numbers is just another outrageous example of the wilful ignorance of bureaucrats failing to understand how catteries function, failing to identify any legitimate factors and ten making up numbers to satisfy themselves.
- Every business has different requirements. Businesses need incentives to grow but DEFRA only provided reasons to contract.
- In all small businesses the number of staff is determined by real things such as availability, ability, age or health, not by arbitrary numbers or anything extrapolated from the advice of some unqualified charity lobbyist.
- When it comes to being employed here, an Ofqal qualification would not get you a job at our cattery - It wouldn’t qualify you to work in any commercial business that deals with tourism, animals or people - the qualities we require are reliability, responsibility, efficient & attentive … words that would never appear in the same sentence as a DEFRA official.
This discussion of DEFRA's regulation fiasco is covered in ten short articles:
Part 1,
Part 2,
Part 3,
Part 4,
Part 5,
Part 6,
Part 7,
Part 8,
Part 9,
Part 10