Questions over zoo licensing are being raised following the release of a report which indicates that an unacceptably high number of zoos in the UK are operating illegally. Is confusion over the classification of 'domesticated' and 'non-domesticated' animals in the current legislation partly to blame? Tracey Khanna reports

In the twelve-month period leading up to September 2001, the Born Free Foundation, an international wildlife charity, independently assessed the status and performance of a large number of zoological collections in the UK in line with the Secretary of State's Standards of Modern Zoo Practice. The charity believes that its findings should be of concern to all environmental health officers involved in licensing and those working to enforce animal welfare legislation in Britain's zoos and wildlife parks. But the published report, entitled Official zoo health check 2000, has been less than enthusiastically received by some local authorities. A "zoo" is defined in the Zoo Licensing Act 1981, as being "an establishment where wild animals are kept for exhibition ... to which members of the public have access, with or without charge for admission, on more than seven days in any period of twelve consecutive months".

The wide scope of this definition means that licensed zoos range from traditional urban zoos and safari parks to small specialist collections such as butterfly houses and aquaria. This wide range of establishments is recognised by the Act, which allows dispensations to be granted for small zoos. However, Defra points out that "dispensations for these types of collection are purely to reduce the number of inspectors to a reasonable level for a small establishment, and do not in any way weaken a zoo's obligation to achieve the levels of animal welfare and modern public safety set out in the Secretary of State's standards." But according to Daniel Turner, the Born Free Foundation's zoo check co-ordinator, the charity has found that as many as one in five of all collections that qualify as zoos under current legislation, such as aviaries in parks, butterfly farms, squirrel sanctuaries and aquaria, are in fact operating without a licence. On the back of the zoo health check report's findings, the charity has written to a large number of councils to inform them of the possible existence of "illegal" zoos operating in their area. In order to determined whether it felt an establishment required a licence, the zoo check team first contacted local authorities asking for information on "establishments with a zoo licence". This list was then assessed against all known animal collections within each constituency, through direct contact with the establishments themselves. The team requested a species list from each "zoo" which, it says, allowed the subsequent identification of those establishments that met the criteria for a zoo, as defined in the guidance, but were not registered with the local authority.

It is estimated that there are around 430 zoological collections in the UK, and as part of its research the charity inspected 104 randomly selected collections, representing around a quarter of UK zoos. The investigation found that: - at least 18 per cent of zoological collections appear to be operating without a licence;
- Ninety-five per cent of species or subspecies kept in zoos are not classified as endangered and 97 per cent are not part of European captive breeding programmes, despite the claim that zoos are making a meaningful contribution to conservation by keeping and breeding endangered species; and
- more than a million unsupervised contacts between animals and visitors occur annually, placing both animals and the public at risk from close contact.

The Born Free Foundation has raised a number of issues which it says should be of concern to local authorities. The organisation accuses EHOs of affording only a low priority to zoo licensing and of drawing too heavily on recommendations from zoo inspectors, rather than making their own decisions over standards within zoos. It also states that the current definition of "wild animal" and animals "not normally domesticated" in the UK is open to interpretation. According to Mr Turner, chipmunks, iguanas, aviary birds, ornamental pheasants, butterflies, red squirrels, chinchillas, wallabies and emus, for example, should fall under the definition of "not normally domesticated" and thus, should require a licence. However, Peter Weardon, an EHO at South Hams District Council and a member of the Government's advisory body, the Zoos Forum, has some concerns on this issue. "While reports like these are useful to keep local authorities on their toes'" he says, "why license animal such as chipmunks?" Alastair Grant, a principal EHO with Dudley Metropolitan Borough Council, and also a member of the Government's Zoos Forum group, feels that the report should be kept in perspective. Mr Grant has worked closely with Dudley Zoo since 1982, and has a special interest in animal health and welfare issues. "There are unlicensed premises out there," he commented. "And yes, some of these unlicensed premises should be." But he points out that there needs to be a balanced view of the Born Free Foundation's findings. "The report has highlighted the odd deficiency, but measures are being taken to improve matters." Another concern raised by the zoo health check is that of exposure to the public of infectious disease, or zoonoses. Zoo check points out that as part of its ongoing investigations, the possible risk of zoonoses is not make clear to the visiting public. The charity alleges that "keepers have been seen feeding animals and cleaning out quarantine areas without protective clothing and potentially listing disease cross-contamination by visiting different enclosures." Furthermore, it states that "people handling animals are rarely asked to wash their hands" and that "in many cases keepers were seen not to challenge situations where the public were observed touching animals without authorisation, often in places where signs explicitly asked the public not to touch the animals."

However, as Mr Grant points out, while there is obviously a need for good signage and washing facilities, different establishments have different policies in place for human-animal contact. He also says that since the foot and mouth epidemic, many zoos have either limited, or stopped completely, contact between animals and people. In April this year, Defra is hosting a weekend training seminar at Bath University for zoo inspectors and local authority officers working in zoo licensing. The two-day meeting aims to address the problems associated with zoo inspections, best practice (including health and safety issues), conservation and research, and ethics. However, it would seem that the response from local authorities to the Born Free Foundation's communication relating to its findings has been fairly disappointing - with just 37 per cent of the local authorities believed to have "illegal" zoos in their area replying to the charity's concerns. This could in part be due to the organisation's past reputation as an animal rights group; the charity has in the past given many local authorities "a hard time" over zoos. But Mr Turner is keen to stress that this is not the case, and that the organisation is in fact a "zoo watchdog" that wishes to see a change in legislation by legal means. It calls on local authorities to help by clearing up any confusion that exists over the definition of a zoo, and the interpretation as to what constitutes "domesticated" and "not normally domesticated" animals.

There are a limited number of places available on the weekend training seminar in April, at a cost of £180 per person. For further details contact Georgina Gorfin on tel: 0117 372 8503.

The Born Free Foundation is keen to work with EHOs to uphold high standards of animal welfare and public safety in zoological collections, providing guidance on legislation, non-mandatory guidelines and other welfare issues. Born Free is in contact with central and local governments, welfare networks, zoo operators and the public. We will contact all EHOs in early 2002. For more information contact Daniel Turner on 01403 240170 or e-mail: daniel@bornfree.org.uk.