Part 5 - DEFRA's Regulations
5.0 Suitable environment
This entire section is not worth the pixel space either, but it’s worth reviewing and ridiculing a few of the mind-numbingly stupid inclusions.
5.1 All areas, equipment and appliances that animals can access must present minimal risks of injury, illness and escape. They must be constructed in materials that are robust, safe and durable, in a good state of repair and well-maintained
No one in our industry deliberately risks injury or sets appliances or the premises up to allow injuries or escapes.
Dealing with unpredictable behaviour is a fucking nightmare and one mistake puts you on every social media page in the area, so safety is at the forefront of everyone’s mind.
How the hell does DEFRA think that a local authority employee is able to assess whether the materials are robust, safe or durable - when if they were qualified to specialise in evaluation and characterisation of coatings and surface stress testing, they wouldn’t be inspecting catteries.
Windows and doors must be:
- escape proof
- strong enough to resist scratching
- capable of being secured properly
Not once did we think to cut windows into all our rooms just so we could let the cats come and go as they please, forget to put the locks on the doors or install titanium cladding on all surfaces.
Pen doors:
Unit doors should open inwards to protect the health and safety of staff. If this is not possible, there must be a documented procedure to demonstrate the safety of staff.
In what alternative reality does the difference between hinge directions becomes a source of danger and why would only one direction require special documentation?
Pen water:
Door openings must be constructed in a way that the passage of water or waste is not prevented. Water or waste must not be allowed to gather because of inaccessibility.
Who creates an imaginary inaccessibility situation and then creates a bogus health & safety clause to deal with it?
Pen Drainage:
Any drainage must be effective to make sure there is no standing or pooling of liquids.
A minimum gradient of 1:80 is advised to allow water to run off.
Waste or water must not run off into neighbouring pens or cat units.
I think that between occupants the DEFRA clown think we’re hosing down a cow stall, because they simply have no idea how to disinfect any room and no idea how any cattery functions.
But they assume that a local authority employee would have the time to throw buckets of water into every pen to check the gradient.
And assume that an Ofqal qualification would allow them to divide the vertical height by the horizontal distance or work out what a 1:80 gradient means.
Pen temperature qualifications:
5.2 Cats must not be restricted to areas that get too hot or too cold, causing them distress. The insulation and temperature must keep some part of the sleeping area between 15°C and 26°C. The temperature must never go below 10°C. Additional heat may be provided by heated beds or pads, but they must not be the main source of heat for the cats. The cat must be able to remove itself from the source of heat.
These temperature requirements have to be two of the most moronic statements coming from a department whose entire existence is based on finding employment for morons.
A local authority employee isn’t equipped to measure temperature.
According to DEFRA's other regulations we have to inspect each cat every three hours which lets all of the heat out, then on top of that there are the scheduled interactions, feeding and toilet cleaning which all have the same effect.
Even if it was necessary to add an arbitrary temperature advisory, the only words necessary are, the minimum temperature in Winter should be X°C and the temperature in Summer should be kept below Y°C.
- Cats survive on every continent except Antarctica and thrive in any temperature from the arctic circle to the Gobi desert.
- A cat’s metabolism is so high that it creates warmth by eating, they are radiators and cats would roast their own kidneys if given the choice to lie in front of a wood burner.
- A hot water bottle or any microwave wax pad are all any cat needs to keep warm, and they can just get up and move to another position as per the regulation. To suggest that this isn’t enough comfort is just more shit from the dysfunctional minds of DEFRA's dolts.
- A convector heater is inefficient and has to be placed near the base of any sleeping compartment - it may need a protective cover and requires circulation - an infrared panel or lamp is far more efficient and is used effectively to keep chicks and piglets alive but does not heat air making it impossible to record an accurate temperature.
- PVC builds are greenhouses in Summer. They require combinations of air-con units, fans or sun shades to keep the temperatures good for people, but as long as they can lie on a solid concrete, tiled or resin floor to cool down cats really don’t care about temperatures.
Exposure:
5.2 Cats must not be exposed to:
- excessive or continuous noise - such as dogs barking
- draughts
There is something wrong with the ability of DEFRA employees to relate to reality, because hundreds of UK businesses are run as kennels and catteries - and they were all granted planning permission and licenses after noise levels and restrictions were considered.
So of course DEFRA included regulations that gives local authorities the mandatory power to close down a cattery if a fucking dog barks within earshot.
And while in one regulation banned draughts, in another mandated ventilation and in another mandated the need for cooling or heating appliances, so long as the cats can’t access them as per 5.1.
More about cleaning:
5.5 Procedures must be in place to make sure housing and any equipment within it is cleaned as often as necessary and good hygiene standards are maintained. The housing must be capable of being thoroughly cleaned and disinfected.
This isn’t a regulation, it’s not policeable, it’s a basic operating requirement to keep everything cleaner than people keep their own homes and pet areas. Units must be inspected each day and kept in a clean condition. This must be done in line with the documented cleaning and disinfection procedure. What documentation? A regulation where the local authority goon has to ensure that we’re using the manufacturer’s suggested bacterial or virucidal dilution ratio is not a regulation or in any way enforcable.
More cleaning:
Each occupied unit must be cleaned at least once each day.
DEFRA has mandated that since no cattery owner can be be trusted to do anything that a local authority employee must check that it was done every day to issue a licence.
More cleaning:
Units must be disinfected between new occupants and when necessary. Effective spot cleaning is allowed.
No spot cleaning is sufficient or effective between new occupants. So if you’re going to make cleanliness a regulation, separate the sentences into coherent instructions.
Pests:
If a pest problem is identified, a pest control programme must be put in place.
The only pest control anyone needs is something to stop the spread of DEFRA’s farcical overreach and incompetence.
Transportation:
5.6 The animals must be transported and handled in a manner that protects them from pain, suffering, injury and disease. This includes considering housing, temperature, ventilation and frequency.
All DEFRA regulations should come with an advisory warning against unnecessary stupidity - the first time 'ventilation' is a thing, but if any cat needs transporting, it will be an emergency and none of this shite matters.
Livestock transportation:
All animals must be transported according to the regulations laid down in current legislation.
We’re in the tourism sector. We do not need links to farm animal transportation legislation when absolutely nothing is applicable to cats or the rest of the sector.
The rest of 5.6 appears to have been written by someone who read an article about leaving a dog in a car on a sunny day and it died.
Valet Service:
Vehicles must be cleaned and disinfected after each collection or delivery of any new cats.
How you gonna police this one?
Demand valet service receipts?
Inspections:
5.7 All the animals must be easily accessible to staff and for inspection. There must be sufficient light for the staff to work effectively and observe the animals. Where practicable this must be natural light, but artificial light must be available. If artificial lighting is used it must be within a range of 10 to 12 hours daily.
We’re not growing cannabis. We don’t need to provide 12 hours of daylight. We’re not going to leave lights on when we’re not open if we don’t want to and we’re not going to waste electricity in winter extending the day length just because DEFRA employees don’t understand the concept of feline ocular requirements, costs or seasons.
When we go into the cattery after dark, we use a flashlight because we don’t want to disturb the entire cattery and upset everyone. And not understanding why we don’t put the lights on is why DEFRA is fundamentally unfit to write any rules for our industry.
A WTF? moment.
5.8 All resources must be provided in a way (for example as regards frequency, location and access points) that minimises competitive behaviour or the dominance of individual animals.
Another pile of pointless excrement copied from another document unconnected to the cattery sector.
Sharing:
If cats from the same household share a unit there must be multiples of all resources equal or greater than the number of cats. Examples of resources include:
- food
- water
- litter trays
- resting and sleeping areas
- enrichment items (such as toys)
5.8 is a great example of why almost every graphic portrays DEFRA bureaucrats in clown outfits and why DEFRA need to be relieved of any further interference in our sector.
The damage they’ve caused by their stupidity is beyond imagination and their total lack of competence and talent is apparent in every word.
I don’t know of any design of any cattery in any country where a double pen was required to have two sleeping areas or where there would be enough floor space to put three litter trays - and these people are just incapable of keeping their incoherence and stupidity hidden.
Distress?
5.9 The animals must not be left unattended in any situation or for any period likely to cause them distress.
- What if they’re distressed during the night?
- What if we're asleep or the cattery is 100 metres from the house?
- Do we have to put our bed inside the pen or pay someone to come round and keep them company?
- How do we determine what amount of time is likely to cause each individual cat stress?
- Do we now have to keep a timer handy or will DEFRA actually get around to letting us do our job?
All cats must be checked often throughout the day. The licence holder or responsible person must visit the cats at regular intervals no more than 3 hours apart (from 8am until 6pm).
If your boss gives you permission to leave your office and check your own pets every 3 hours that would explain why DEFRA doesn't function - But in the real world owners are out at work 10 hours a day and cats sleep almost all of that time.
Anyone engaging in DEFRA’s ongoing torture and sleep deprivation regime should be closed down. Cats don’t want to be disturbed and don’t want to be distressed by people turning up every few hours without feeding them or interacting with them.
OMG! They allowed the owner to make a decision!
Cats must also be checked as often as needed for their individual health, safety and welfare.
This the only line in 5.9 that’s worth including and worth observing … “as often as needed” which overrides the rest of the rubbish they imagined were what this sector needs.
DEFRA threw in a few zingers at the end and made a pigs ear out the entire section - words and ideas that make absolutely no sense, have no scientific basis and are dangerous, ineffective and unworkable - rules that are optional when they should be mandatory and contradictory when they should not be included at all.
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