Rabbit Advocacy Animal Matters


                                     COMPANION RABBIT WELFARE REPORT

                                      Prepared by the Rabbit Advocacy Group of BC
                                      C 2005, Sue Collard & Carmina Gooch                                    

If the material in this report is reproduced in part or in full or cross posted on any internet site we request that the authors be credited with their work. 


This proposal supports those made by other groups including VHS, AAS and the many letters written by individuals over the past decade. In particular our submission addresses with specific reference to companion rabbits three areas of concern raised, by the Vancouver Humane Society (Animal Welfare in Vancouver. A Report from the Vancouver Humane Society, 2003): 

(1) broad animal welfare problems of protection, care and treatment including spay/neuter legislation

(2) pet store regulation including standards of animal care in pet stores, the provision of species appropriate environments in stores, and the provision of care information to customers at the point of sale; and

(3) methods using for dealing with “problem” populations of either wild or feral and domesticated animals, including rabbits. 

As the VHS proposal noted, increasing public concern over the care and treatment of animals has occasioned a regulatory and legislative void that has been left for local municipalities to deal with.  Equally obvious is that public perception of broad and companion animal welfare and corollary animal control issues for dumped “domestic pets” is also changing with: increased awareness of broadly environmental considerations; increased attention paid to the humane treatment of all animals; and the solicitation of a greater diversity of opinion in decision-making processes. 

As the point of sale and the point at which consumers are supposed according to bylaw provision to be provided with information adequate to the care of their purchases, pet stores are certainly implicated in the many instances of neglect, surrender and abandonment that affect thousands of companion rabbits. To simply say that they are responding to customer demand in supplying rabbit livestock, or to suggest that responsibility for companion animal care is solely the responsibility of the owners or of municipal governments is an abrogation of responsibility on the part of the pet industry. 

Responsibility is a central concept that informs our proposal. While we agree that there are irresponsible owners, there are also irresponsible pet businesses. The many individuals and groups who deal with animal rescue, sheltering and rehabilitation, as well as animal control, cannot be expected to fill in the moral, practical and fiscal void that exists between the two solitudes of individual and business responsibilities. However, municipal governments can help regulate this situation through the enactment of progressive and proactive policies that support all human stakeholders as well as enhancing current animal welfare provision. 

As regulation appears to be a necessary evil, and as current regulation has not been as effective as it could in protecting the welfare of companion rabbits in either the chain of sale and resale or in the protections offered to the consumer, we propose that each of the Lower Mainland municipalities opt for the most elegantly simple solution and prohibit the sale of live rabbits - or better still any live animals -  from pet stores. While our focus is specifically on rabbits it should be noted that many of the points discussed apply to more familiar companion animals (dogs and cats), to exotics (birds, reptiles, hedgehogs, sugar gliders, hedgehogs, ferrets) and to “starter” or “pocket pets” (guinea pigs, rats, hamsters, degus, mice), all of whom continue to be sold from a number of locations across the municipalities.  

Because rabbits are “common” animals, their care and well-being is thought self-evident. As we will indicate, this is far from true and companion rabbits do suffer and die because of prevailing misconceptions and inaccuracies that are not being corrected by the pet industry, and are not or cannot be addressed in current municipal pet store legislation. A primary concern of this proposal, is then one of companion rabbit welfare. A secondary consideration is that current bylaws allow for little in the way of consumer protection. If live animals are to be sold as a “product” surely the municipalities must agree that it would be in the best interests of the public if some guarantees were written in to their purchase, as it is with puppies and kittens. 

We believe that, in the absence of municipal agreement on a moratorium or prohibition on the sale of live animals from stores, our concerns around both companion rabbit welfare and protection and consumer protection can be addressed by strengthening and expanding extant bylaws provision to: 

            -enshrine conditions of humane treatment that are on a par with current animal   

    welfare rather than pet industry recommendations

           -expand existing clauses to include specific reference to rabbits,

           -strengthen and expand those clauses relating to information required to be  

    provided to purchasers.   

Rather than being specifically directed at any one municipality we believe that a coordinated policy across municipalities is required. It is common sense and an all too frequent occurrence that the point of sale and the eventual location of the problem (whether this be road kill, a dumped animal, or shelter or rescue group surrender) are not necessarily the same. One city’s laxer bylaws on the sale of animals or provision of appropriate care and education should not be allowed to become another city’s problem.  

Current bylaw provision 

Our research indicates that as the situation currently stands there is no bylaw provision specific to rabbits in any of the bylaws we accessed, and some municipalities appear to have no by laws governing the sale of any livestock from pet stores, for example, West Vancouver.  

As such, rabbits are covered under general but not specific provision in current municipal regulations. These provisions typically cover points such as: the necessity for quarantine areas for sick animals, the necessity for qualified veterinary attention, the use of trained and knowledgeable staff, the establishment and maintenance of a Pet Register to record all transactions where animals have been acquired or disposed of. 

Some bylaws do contain specific requirement for birds and exotics, and some contain specific clauses that relate to dogs and cats only. For example, the City of North Vancouver by laws indicate that with specific reference to dogs and cats “pet establishments” are required to maintain the name of the supplier, breeder or method of acquisition, the date of purchase or acquisition, and a description of the animal purchased or acquired (The Corporation of the City of North Vancouver, Bylaw No 7040, Section 8 “Records of Purchase, Sale or Acquisition”.)  

We are uncertain what if any principles govern the selection of which companion animals require specific legislation, and to some extent we believe that the current bylaws’ silence on rabbits and small animals reflects something of a prejudicial hierarchy of “acceptable” pets. Rabbits and small animals suffer from their commonness, from their relatively easy acquisition, and from an amazing lack of consumer education and awareness in ways that dogs and cats do not. We do not believe that they and their companions should therefore suffer from lesser protections, lower standards of care, or the knowing or coincidental perpetuation of misleading and out of date information. Ignorance is no defence on the part of individuals or businesses.  

In particular, we request that existing bylaws be amended and/or strengthened in the following areas: 

1.       In common with current information on rabbit welfare, enhance animal welfare standards provided to rabbits in stores through bylaw specification on the following: 

(a) increased cage size  - the rabbit should be able to make at least 3 hops or the cage should be 4 times the body length , the rabbit should be able to stand upright in caging on its back legs ,with a minimum cage size of 4’ x 2’ for a single or paired BABY rabbit; 

(b) a systematic use of environmental enrichment items such as suitable toys (cardboard rolls, organic apple twigs and digging boxes); 

(c) a systematic use of “safe houses“ for the rabbits to retreat to when they choose in order to enable rabbits to engage in species specific crepuscular behaviour; 

(d) the housing floor should be covered to provide sufficient traction for rabbits to move around and engage in a normal range of movement, and where shavings are used as flooring aspen shavings are preferable as both pine and cedar can cause problems; 

(e) littermates should not be split up where possible, but careful consideration should be given to multiple housing of baby rabbits in larger octagonal cages in order to ensure that no crowding takes place; and  

(f) rabbits should be fed a diet that mimics as closely as possible their diet in the wild including hay as a staple, in addition to the more commonly seen commercial pellets, as hay provides the long fibre necessary to a healthy gut and teeth. Care should be taken to ensure that their diet in the store resembles what they are used to, and new food items including hays should be introduced gradually. 

These recommendations introduce specific housing and enrichment requirements for rabbits to replace general recommendations. 

2.       Pet Registers should include all pertinent information regarding their acquisition of rabbits including the name(s), addresses, and where pertinent business licence information of the breeders, brokers or any other person from whom rabbits are obtained, the names of the wholesalers, the time in transit from breeder/wholesaler to the store site.  

This recommendation extends the same requirements to rabbits as those for dogs and cats, puppies and kittens. It expands requirements to include transit time as transit is a frequent stressor – if not killer – of pet livestock. 

3.       Rabbits placed in stores should be veterinary certified as healthy by a qualified and experienced rabbit veterinarian at the time they are placed in the stores.  

This recommendation expands some existing bylaws covering cats and dogs to include rabbits (for example the City of Richmond bylaw 7538 12.6.2) 

4.       People who wish to purchase a rabbit from a store should be provided with the history of their purchase including age, sex if it is possible to determine this, breed or breed mix, the name of the breeder, and the point of origin of the rabbit.  

This recommendation introduces a new element into bylaws in the interests of consumer protection and consumer choice. 

5.       Adequate information about rabbit care congruent with latest animal welfare findings including, feeding habits, exercise patterns, and the need for social contact must be prominently displayed and provided to purchasers at the point of sale, including the fact rabbits should not be sold as outside “hutch” animals, including the necessity for spay/neuter in order to ameliorate behavioural and known health issues with rabbits.  

This recommendation strengthens and expands existing bylaws on the provision of information to purchasers. (We have included consideration of rabbits as hutch versus indoor companions in the interests of optimum welfare conditions for rabbits and for the reasons mentioned in the attached report) 

Background: The Pet Industry and the Public 

In our opinion, removing live animals from sale is congruent with improved animal welfare standards, with increasing public concern with animal welfare issues, and in the long term is more fiscally prudent. If there were no live animals sold from pet stores there would, for example, be no need for bylaw enforcement regarding the sale of live animals, no cruelty and neglect investigations of stores by Special Constables or the RCMP, and no need for the pet industry to spend time and effort on the research into and monitoring of bylaws in Canada and elsewhere, or in lobbying to allow for yet more animals to be kept in captivity.   

For example, the Pet Industry Joint Advisory Council (PIJAC) website “Legislative News” section states the following with reference to Quebec: “Changes to the province’s wildlife regulations were finally published in the official gazette on October 30th.  The changes will allow for the ownership in captivity of sugar gliders, African pygmy hedgehogs and kangaroo rats. Changes come into effect on November 14th and mark the end of numerous years of efforts on behalf of PIJAC Canada and its Quebec division to bring about these changes”(our emphasis). PIJAC would seem directly involved in lobbying at the provincial level and keeps an effective watch on municipal bylaw issues throughout Canada, as is congruent with its primary mission to “represent and promote the interests of all segments of the pet industry”. 

Whether or not it chooses to acknowledge its equally valid and pressing responsibilities to both the public and the animals it sells is somewhat less certain. There is little doubt in our minds that as the industry body responsible PIJAC and by extension the pet livestock industry is complicit in the ongoing problems of companion animal welfare. While we are aware that PIJAC has worked on such issues as approaches to animal control as a stakeholder in the National Companion Animal Coalition, it should be noted that this document was directed toward the municipalities’ needs to enact by laws, rather than to the pet industry per se, and that animal control issues tend to focus on dogs and feral cats. 

In brief, it would appear that PIJAC sees animal control issues – the end point of a chain stretching from breeders to dumped, neglected or abused companion animals - as either ones of personal responsibility on the part of the “pet owner” or of local government. This begs the questions of where and how the pet industry is accountable, and to what extent it is accountable for actions whose origins lay as much in the purchase of live product as they do elsewhere. It also begs question of whether or not the public purse should pay for problems that, with respect to rabbits, small animals and exotics are certainly not being addressed by pet industry in any formalized way.  

While it is not within the scope of municipal governments to address some of these broader issues we believe it is possible for the municipalities to have a positive effect on the overall standards of companion animal care from point of purchase to eventual home through careful consideration and the enactment of proactive bylaws at the point where animal welfare, pet industry and consumer concerns meet, the pet store. 

The costs of dumping and animal rescue: passing the buck … 

I was talking with someone over a photocopier as is common these days, when the topic veered toward people and pets. The person I was talking with explained that she and her husband lived on a dairy farm and that over the years they had had innumerable animals dumped off at their barn including litters of kittens as young as 3 weeks old, a series of dogs, and the occasional small animals. This person went on to explain that she and her husband personally had the animals checked and given appropriate treatment by a veterinarian and then placed them with suitable homes. This increasingly common story indicates both the prevalence of pet dumping and the costs that are borne by individual members of the public.  

In our opinion, there is little doubt that the unfortunate combination of a ready supply of “pet rabbit stock” with (1) a lack of specific regulation on standards of rabbit care, (2) lack of education on and awareness of the ethology of the rabbit, and (3) the lack of a coordinated policy and by laws governing the sale of live animals at stores contributes to the ongoing surplus of unwanted “pet rabbits” that are regularly dumped at shelters, thrown out in parks, abandoned in apartments or are otherwise left for “someone else” to care for.  With rabbits you might say this is literally a case of passing the buck, and to complete the pun yes it does cost doe. 

Breeders and pet stores: the ready supply of rabbits 

Our ongoing research into rabbit breeders in BC indicated that in 2004 - 2005 there were over 30 breeders of pet stock rabbits listed on readily available web sites, with about 10 meat rabbit breeders listed, some of whom also bred pet stock.  

http://www.rudolphsrabbitranch.com/rrrbrdint.htm  (updated link)
http://pub50.bravenet.com/freelink/show.php?usernum=4288379305 (updated link)  

There are also a number of local producers in the Vancouver area who do not necessarily list on the internet. At least one person in Vancouver placed a classified ad on a breeder for sale/wanted page asking for four does and a buck, at least one person in Maple Ridge was advertising fryer rabbits for sale at $15.00 each, and another person in Langley was asking for “white fryers”. BC also is the home of the Canadian Centre for Rabbit Production and Development (Surrey) run by Robert McCroskey, who has continued a campaign over the past 5-10 years to increase awareness of meat rabbits. 

Actual figures are probably well in excess of this number. Breeders will frequently refer interested buyers to other breeders who may not be internet listed, and for every formal breeder there are innumerable backyard breeders and/or people who either knowingly or in ignorance let their rabbits breed.  

While there may seem be many “good breeders” based on text and pictures available on individual websites, there appear to be a number of breeders whose breeding environment  falls short of optimum standards for animals or who advertise they “cull” or in one instance “cull heavily”.  As breeders are quick to point out, while culling for breed and other imperfections does not necessarily mean that animals are killed, in some cases there is little doubt that a failure to conform to type means certain death (a sign that breeders operate with a more totalitarian mentality than most Canadians are comfortable with).  And as these pictures from breeder websites indicate, a life as a “breeder rabbit” confined to a rusty wire bottomed cage in a shed, with little else but water and pellets is far from congruent with the past decades of research into rabbit welfare. 


Our research also indicated that for some people breeding is a lucrative business, one whereby the animals’ well-being is of little or no relevance. They appear to be nothing other than commodities selected for short term saleability and maximum profit: several rabbit breeders were also involved in breeding other animals, including dogs and guinea pigs. And, as a brief aside, several breeding businesses were started or run by teen girls, many of whom go into business with their parents, or start a breeding business as a result of 4H involvement, a possible area for further consideration and intervention.   

From the website of Susan A. Brown, DVM, on humane requirements for housing rabbits:    http://www.hrschicago.org/dietcarefr.html 



            House rabbits should never be kept completely confined to a cage. Exercise is vital for the health of the rabbit. All too often we hear well meaning, but poorly informed, people describe rabbits as easy to keep because “they can be caged and don’t take up much space!” This idea has led to many rabbits being caged most of their lives with the distinct possibility of developing both physical and behavioral disorders. They are designed to run and jump and move about a large area.

To confine a rabbit to a cage exclusively to a cage can cause several problems:

¨       ¨Obesity – caused most often by a diet too high in calories coupled with a lack of exercise

¨       ¨Pododermatitis – Inflammation of the feet caused by sitting in a damp or dirty environment

¨       ¨Poor bone density - Rabbits that are continually confined to a small cage can exhibit marked thinning of the bones which may lead to more easily broken bones when handling

¨       ¨Poor muscle tone - If the rabbit can’t exercise, the muscles, including the heart, will be underdeveloped and weak

¨       ¨Gastrointestinal and urinary function - A rabbit that sits all day in the cage with little exercise can develop abnormal elimination habits

¨       ¨Behavioral problems - Continually caged rabbits can exhibit a wide range of abnormal behaviors including lethargy, aggression, continual chewing of the cage bars, chewing fur (obsessive grooming), and destruction of the entire contents of the cage.

A cage can be used as a “home base” for part of the day or it can be open all the 

time within an exercise area. The cage should allow the rabbit to stand up on its hind legs without hitting the top of the cage, provide a resting area and space for a litter box. 

Animal Welfare Institute   http://www.awionline.org/Default.htm

Excerpt: Housing

a)    Housing must allow for social interaction and include physical substrate for digging, playing and hiding. Rabbits must be able to make normal postural adjustments, including sitting up on hind legs and exhibit normal behavior such as hopping, digging, hiding, grazing, grooming, sun bathing, dirt bathing, and exploring.

Excerpts: Space Requirements

a)    Housing should always be sufficiently sized to allow normal postural adjustments with freedom of movement and adequately enriched to prevent boredom.

b)    Housing shall be sufficiently spacious to allow all animals three hops in one direction, allow the rabbits to move around and feed and drink without difficulty, enable all the rabbits to lie on their sides at the same time without overlaying another rabbit, and be of sufficient height to allow the rabbits to sit upright on their hind feet without their ears touching the top of the hutch or cage. Rabbits need sufficient space to hop around not just turn around. They need enough space to allow them to spread out, particularly if it gets hot. It is essential that they are not crowded. 

From breeder to pet store 

In the US individual small breeders will sell to wholesalers who in turn sell their product to stores. The mortality statistics for rabbits in transit to stores is high, with an estimated 20 – 30% of rabbits dying before reaching their end journey. Further numbers will die due to the stress of early weaning for sale, and transitions in environment from store to their new “owners” home. Both US and UK newspapers have featured stories about the inhumane treatment excess or sick pet store rabbits receive including suffocation and beating to death. It would perhaps be optimistic to think no such abuses are occurring in Canada. 

To date we have been unable to obtain information on where local pet stores obtain their stock. We know from anecdotal evidence that some small store owners are approached by individuals whose rabbits may have had a litter. This would not answer the question of where larger chains like Petcetera obtain their rabbits.  

The issue of “sourcing” becomes one of interest to municipalities when it overlaps with public health issues, or where it possibly affects other businesses.  Certainly rabbits can carry some, albeit few, zoonotic diseases, but incidences of disease transmitted by rabbits are extremely rare. Certainly there is provision in existing bylaws for reporting sick animals when and where zoonotic or transmittable diseases are suspected, and for segregating sick animals. 

However, while stores are required to keep records of where they obtained their livestock, there is no requirement that this information be passed on to consumers. This makes obtaining accurate information about ones’ purchases virtually impossible. Caveat emptor is impossible in the absence of a requirement for adequate information to be given to the consumer, because it is impossible to make an informed and rational decision based on an absence of information.  

For example, it would be impossible under current bylaws for people to have any idea of where their rabbits came from, unless this information was voluntarily provided. This makes it impossible to check if their rabbit came from a reputable breeder, or a breeder or business who had been previously cited for animal cruelty or neglect. Similarly, if rabbits are not checked by an experienced rabbit veterinarian it would be hard to determine how healthy the rabbits are which means that consumers may well be purchasing sick stock. 

With specific respect to rabbits, the provenance of the supply going to large scale stores is a possible concern. There have been a number of spontaneous outbreaks of viral hemorrhagic disease (VHD, also known as rabbit hemorrhagic disease or RHD), a lethal calicivirus introduced as a rabbit control measure in Australia and New Zealand, in rabbits in the US.  At least one of these outbreaks took place at a wholesaler where rabbits were being temporarily housed prior to being shipped out for sale.  

http://www.rabbit.org/care/vhd.html (updated link) 

Obviously it would be prudent to establish that any rabbits that might be imported from the US for sale were free from signs of VHD, or had at least been vaccinated for the disease. More importantly, as an issue of consumer choice, people should be able to determine for themselves whether or not they would prefer to buy “livestock” that originates from countries where VHD is present. To date, we are not aware of any outbreaks of VHD in Canada. As the RHD (rabbit hemorrhagic disease) website and subsequent breeder concerns indicate, RHD can pose a huge threat to breeders who have spent years developing lines for show and sale, outbreaks have generally involved circle culls of hundreds or thousands of rabbits, and the disease itself appeared to present in a far more painful and lingering way than initial Australian government reports suggested. 

Pet store purchases 

In addition to readily accessible breeders there is an appalling number of pet stores in the province that sell live rabbits, including the Petcetera chain with 16 stores in BC, 10 of which are in the Lower Mainland, a number of Pet Habitats, and several small independent shops that will sell a variety of animals from puppies and kittens to spiders.  

Petcetera frequently sells sale priced and appealing baby bunnies for $29.95, and prices for pet rabbits we have observed at a variety of locations usually appear to be anywhere from “free with cage” to approximately $60.00, with some breed specific breeders selling breeding stock to other breeders for $80.00 - $125.00. The relatively low cost of rabbits in comparison to dogs and cats makes them appear a cute, fuzzy, easy to care for, and cheap alternative to puppies and kittens.


 Animal Advocates Society    http://www.animaladvocates.com/rabbits

In recent years there have been several instances in the Lower Mainland where pet stores have been investigated for operating with insufficient levels of care for the animals temporarily in their charge. In addition, a large number of breeders have had animals seized. 

At least one of these stores, the Burnaby Pet Habitat was the subject of complaint for a large number of years, and eventually had its animals including rabbits seized by the SPCA in 2005, pending an investigation. 

Pet store owner charged with failing to provide proper care  Animal protection agency says numerous complaints have been made over dirty, crowded cages
Elaine O'Connor
The Province
Thursday, May 05, 2005
A Burnaby pet store owner will appear in court next month to face charges of animal cruelty after a B.C. Society for the Prevention of Cruelty to Animals bust.

Thomas Peters, owner of Pet Habitat in the Brentwood Town Centre, is accused of failing to provide proper veterinary care for a sick animal and keeping animals in substandard conditions.

"Over the past five years we've received numerous complaints on this pet store," said senior animal protection officer Eileen Drever.
 The agency claims a sick puppy was found "with its ribs visible, lethargic and depressed, with laboured breathing" and birds were found with overgrown nails in dirty, crowded cages. One bird had a broken leg. Rodents were kept
in cracked fish tanks.
"The problem with this gentleman is we have advised him over and over again to seek immediate veterinarian care for any sick or injured animals and he has failed to do this," Drever said.
But Peters, who has owned the store six years, disputes the claims, and accused the B.C. SPCA of going overboard with a spate of inspections at pet stores in the region.
"I think basically, the SPCA had a vendetta against all the pet stores," he said.
"We welcome them to come by, but all of a sudden there is a big change [in standards] and they don't even tell us what's going on, they just say this is wrong, that's wrong."
 He explained the ill animal was a wire fox terrier with a cold. It was eventually put down.
"It was under treatment here in the store, and they said that I had to take it into the vet and they figured because I hadn't taken it that I hadn't been doing treatment in the store and that was considered neglect."
Peters has been summoned to appear in court on the charges June 2. He plans to dispute the charges.
If convicted of animal cruelty under the B.C. Prevention of Cruelty to Animals Act, he faces up to six months in jail, a maximum $2,000 fine and a prohibition on owning or keeping animals.
 Peters said pet store owners have asked the Pet Industry Joint Advisory Council of
Canada (PIJAC) to intervene and clarify care standards with the B.C. SPCA.

Other pet stores are being allowed to expand to further locations despite being previously investigated and cited for substandard conditions for the animals they sell. For example, the Maple Ridge Mr. Pets has announced the opening of another store at a Commerical Drive location this fall. 

About Mr. Pets (from a newspaper advertisement)

Mr. Pet's began in 1996 as a small pet supplies and fish store in Port Coquitlam, and quickly branched out to include another store in Maple Ridge in 1997. With the success of these stores well under way, Mr. Pet’s also started a small wholesale company in Port Coquitlam. The Port Coquitlam and Maple Ridge retail stores quickly outgrew their spaces and expanded to better serve their growing clientele. The expansion of the Maple Ridge store included a second story with small animals, fish, reptiles and other exotics. In 2002, another store opened in Mission to serve the farm industry and quickly excelled as a feed and pet supplies store. Not long after, the growing Port Coquitlam-based wholesale company moved to Mission and merged with the retail store. With future plans to add more stores in British Columbia, Mr. Pet’s will be coming soon to a neighborhood near you.

Mr. Pet's
1714 Commercial -- Opening Soon
East Vancouver BC
Telephone: (604) 872-0115

150 animals seized from Maple Ridge pet store
January 7, 2005

A Maple Ridge pet-store operator promised yesterday to improve conditions at his store following the seizure of 150 animals by the Society for the Prevention of Cruelty to Animals.

Greg Penno, co-owner of Mr. Pets, said the failure to respond to earlier SPCA warnings was the result of the busy holiday season.

"It was a small, little incident that kind of escalated into something larger," said Penno, whose company also has outlets in
Mission and Port Coquitlam.

The SPCA had previously given the pet store a formal warning over overcrowding, lack of proper perches and having water dishes instead of water bottles for the small animals. The lack of compliance resulted in the seizure of 24 birds, six rabbits and 120 rodents. Charges are pending.

"I'm investigating why that [complying with SPCA rules] didn't take place," said Penno. "I'm quite upset by that. We're going to rectify these issues."

The SPCA said the store had been visited "repeatedly" and told to make changes.

"We had been working with the manager or owners of the pet store and they failed to comply," said Eileen Drever, the SPCA's senior animal-protection officer.

The seized animals are being cared for at an SPCA shelter. 

Again, though not specifically covered under bylaw provision for pet stores, municipalities could further support animal cruelty and neglect investigations of pet store businesses by introducing provisions that support the suspension of business licenses for pet store operators convicted of cruelty or neglect, and by making the issuance of new licences where the business and the proprietors are substantially the same subject to stringent licensing requirements.

Pet store marketing and misperceptions about rabbits 

In our opinion a key issue in rabbit welfare and for the interplay between rabbit welfare and municipal bylaws is the misperception that rabbits are small “starter pets” suitable for young children and who require minimal attention, minimal housing and care, and who are relatively short lived. The reality is far different. Some rabbits are larger than small dogs (15 -25lbs) and when properly cared for they live on average as long as a large breed dog (8-12 years, with some rabbits living as long as 17 years). Their sale as “starter pets” speaks to misleading pet industry marketing and calls into question the adequacy of current pet store regulations in operation in municipalities, specifically clauses that require purchasers to be provided with written instructions on the proper care and feeding of their purchases.  Any instruction should be drafted by, or in conjunction with, well-informed rabbit welfare groups or personnel.   

This is partly because there are no guarantees as to the adequacy of the information provided. However, many consumers will take tacit cues from the environments they see modelled in the stores’ own use of certain types of housing and the presence of absence of foods, enrichment items and litter boxes. As the municipalities are well aware, those stores that care enough will most likely model their care and provision of livestock on PIJAC standards. Equally well known is the fact that PIJAC standards lag behind animal welfare practices and therefore cannot stand as an adequate model for companion animal standards.  

One example would be the continuous use of limited size smooth bottomed “fish tank” housing for rabbits in many stores. Anyone who has owned or lived with a companion rabbit knows that rabbits are extremely reluctant to move on surfaces that provide them with little or no traction (for example, my rabbit will not run on the tile floor in my kitchen). Rabbits caged on these types of surfaces may therefore be deprived of a normal range of movement.  

Perhaps there might be a minimal justification for this if their stay in the store were of short duration, but the same bigger and “older” rabbits are occasionally seen for a month or so in stores. With rabbits in particular there appears to be some confusion between housing and “product display”. In addition, nothing is known of what happens to those rabbits who are not sold. Are these rabbits returned to the wholesaler or breeder? If so, what happens to them at this point? Does “dead stock” translate into dead animals? And should consumers have a right to know this? 

In perpetuating the inaccurate portrayal of rabbits as an inexpensive starter pet, pet stores promote a picture of companion rabbits that is not only financially inaccurate but also exacerbates continuing misunderstandings of the complex needs of companion rabbits. Would that inexpensive pet store bunny seem as attractive to impulse buyers if they knew that it required 12 years of specialized veterinary care, required spay or neutering, could not be kept as a caged animal, or developed other habits such as chewing electrical cords?    

Our observations and those of the House Rabbit Society indicate that bylaw provision to the contrary, little or no information is provided to buyers when they purchase rabbits. In “The Plight of Pet Rabbits (www.PETroglyphNM.org) Margo de Mello, a Director of the HRS notes “No pet store that I know provides any sort of pre-sale counselling and education to potential purchasers.’ We have certainly had little success in obtaining even basic rabbit care information from stores selling pet livestock, for example, and when obtained the rabbit care information appeared to comprise a shopping list for product that was mostly inadequate to the needs of a grown rabbit or that epitomized minimalist standards, as the attached information indicates. 

Further problems occur when rabbits are sold or adopted as “hutch animals.” We have seen numerous instances of what can only be termed animal neglect (benign or otherwise) based on this common myth. To give a recent example from our experiences, a neighbour “rescued” a rabbit from a building where it had been kept outside on a balcony in an 18” cat carrier for approximately 3 months.  This young rabbit was extensively urine stained and showed a number of signs of distress including excessive grooming. Balcony rabbits are a common experience for anyone who has been involved in rabbit rescue or welfare activities.  

An isolated life outside is inappropriate for a social animal that commonly lives in groups, and is as least as inappropriate as chaining a dog outside on a permanent basis in part because of the equally limited range of movement hutches provide. Again, we believe the perpetuation of the “hutch animal mythology” reflects current but changing cultural prejudices around companion animals: if it is inappropriate to keep dogs chained outside permanently it is equally inappropriate to keep rabbits penned outside on a permanent basis. 

In the UK the “Pet Advisory Working Committee on Rabbits Report” made a number of observations regarding rabbit welfare that are pertinent here. First, in applying the widely adopted “Five Freedoms” standards for assessing animal welfare to domestic rabbits, they note that the “freedom to express normal behaviour” indicated that domesticated rabbits should have the companionship of other rabbits or “substantial daily contact” with their owner that includes a minimum of an hour of human-companion animal interaction including petting, grooming and play. The House Rabbit Society, a US based charity with a number of international chapters that has been operating for close to 20 years, further suggests that indoor rabbits require significant periods of exercise time, usually 3-4 hours of free run time per day. While we agree that exercise time is important, even more important is the fact that when animals are kept separately and are not allowed to interact with their “owners” it affects the quality of the human-animal bond, leading to increased surrenders. 

Although this report allows for hutch living they indicated that for full- grown larger rabbits hutch size should be approximately 6-7’ and they mention an additional exercise area that is “as large as possible.”  We have seen no caging of this size for rabbits in local pet stores, and most “starter cages” are a scant 2’ in length. Hutch living is not recommended as outside rabbits can be subject to predation by determined predators, most hutches are insufficiently well constructed to provide adequate shelter, many are of an inadequate size, and outside rabbits are more subject to neglect and disease. 

A third and related issue, which we will not address here, is the current failure to define what constitutes the skill, knowledge, ability and training necessary for the humane care of pet store rabbits. Bylaws do contain general provision under the Duties of Pet Store Operators to ensure that animal care attendants are adequately educated in these respects (for example, City of Richmond By Law 7538, 12.1.1 (a)) However, our experience suggests that lack of specification leads to variability in application, with the degree of knowledge demonstrated by staff varying by considerable degrees. 

                                             From pet stores to ferals 

There is little doubt that if permissible, rabbits will continue to be sold from pet stores and by breeders in increasing numbers. Rabbits are the third most popular mammalian pet in the UK, the US and other parts of the world, such as Japan.  Pet industry figures indicate a growing market for both rabbits as livestock and for rabbit supplies, including an increasing pet rabbit speciality food market. In some EEC countries there was a 10 – 15% increase in revenues from the sale of pet rabbits and supplies over a five-year period and a slow but significant increase in revenues was projected to continue. While good for the pet industry, there are no signs that this is good for the rabbits. We can only expect rabbits to become more popular and as they do, we can only expect to see more problems with dumping, rescue and control. 

We can confirm that some pet store rabbits that are sold eventually make their way to local rescue groups or to shelters. To cite just one example, Vancouver Rabbit Rescue and Advocacy listed at least one such rabbit on their website, Timmy. This rabbit was eventually purchased by Vancouver Rabbit Rescue and Advocacy. Timmy was sale priced at the Grandview Petcetera because he has a medical condition that requires ongoing veterinary attention every couple of months, maloccluded teeth. We are aware of several other instances of pet store rabbits making their way to rescue groups, some after only a matter of days. In at least one of these instances people attempted to return their latest impulse buy to the store, without success. 

Pet dumping and the “shelter” situation 

Many other rabbits continue to be dumped at well known dump sites such as Jericho Park, Richmond Hospital, and underneath the Skytrain line in North Surrey. Only a very small percentage of these rabbits will live to survive, let alone be captured by animal control officers and rehomed through pounds/”shelters”. The SPCA’s aged and outdated buildings

and mobile structures have too little space for too many animals and the situation for rabbits and small animals is particularly bad.   

For example, we are aware that despite a “no-kill” policy in operation at SPCA facilities, healthy rabbits are certainly under threat of being put to death as unadoptable when, in fact, the issue is whether they can be moved fast enough. Over the past year there have been a number of listings on the Brindleweb Pet Rescue web site that indicate SPCA rabbits  are at risk when the numbers get too high or if they’ve sat too long. 

From the Brindleweb messageboard http://www.brindleweb.com/rescuebb
Subject: Re: a lot of rabbits to be killed by a shelter?

"Rabbit Hutch" Posted: Fri Sep 09, 2005 11:53 pm Post subject: Rabbits to be put to sleep.
One of the local animal shelters will be putting to sleep half of their bunnies.

We need help to place 12-14 ASAP.....

There is a lot of chatter on Brindleweb about rabbits that may be killed for space at the Richmond SPCA.


Zanes zoo Posted: Thu Sep 22, 2005 2:59 am

...If they are to be destroyed then something needs to be done…

Rabbit Hutch Posted: Thu Sep 22, 2005 10:20 am
I did call head office the day I found out and posted about the 12-14 rabbits.....not even a call back....very disappointing indeed

....sadly this is *why* I got into small animal rescue....I never had a small animal....I was a dog walker.

http://brindleweb.com/rescue/index.html Posted: Sat Sep 24, 2005 12:08 am by Small Animal Rescue Society

He just died in my arms Thank God someone found him and brought him in. 

Rabbit groups have also heard from members of the public who are unhappy that the SPCA has appeared unable or unwilling to capture stray or dumped rabbits. Perhaps this is an issue that should be addressed by those municipalities who have agreements with formalized groups around animal control. 

However, many groups suspect that because of a second prevailing belief about rabbits, - that they can easily be released into the wild and will rehabilitate quickly – increasingly large numbers of rabbits are simply being dumped, so that the numbers of rabbits that end up at “shelters” or at rescue groups represents only a fraction of former “pet rabbits”. In turn, the dumping of unsprayed or neutered rabbits contributes to established, and in relatively rare cases, new feral rabbit colonies.

A rabbit’s breeding cycle is 31 days, some rabbits will breed as young as 15 weeks, and rabbits can be impregnated again within 24 hours of giving birth... Given the prevalence of dumping and the rapid breeding cycle of rabbits, mandatory spay neuter regulation for companion rabbits sold to individuals is as essential as spay/neuter legislation for cats, and information regarding the necessity for spay/neuter must be provided at the point of sale. 

Rabbit Rescue and Rabbit Control Issues 

The need for a more comprehensive approach to dealing with the issues surrounding companion rabbits is indicated in the fact that there are a burgeoning number of rabbit rescue groups in the Lower Mainland. Companion rabbit rescue and rehabilitation by small independent rescue groups accounts for the majority of rabbit rescue in BC. For example, one small group, the Small Animal Rescue Society (SARS) www.smallanimalrescue.org has consistently had more rescue rabbits listed for adoption on the Petfinder site than the total combined rabbits listed for all Lower Mainland SPCA Branches. This figure was derived by simply counting the numbers of rabbits listed for adoption on the respective Petfinder pages on 3 separate occasions over a 6-month period.  

While not completely accurate, it is certainly significant that the general scope of the findings were the same each time the numbers were examined. In this instance the costs of caring for dumped and surrendered rabbits is borne by small groups operating with highly limited budgets and a core of dedicated volunteers who will offer temporary foster homes until animals can be adopted.  

In the Lower Mainland there are already 3 groups who deal either specifically with rabbit rescue or whose work deals with a large number of rabbits. And given the many categories of use that rabbits inhabit – companion animals, experimental animals, meat and fur animals, endangered species -- we estimate that there are over 20 groups in BC’s Lower Mainland whose mandate could include rabbits, including 8 SPCAs, 2 City Animal Shelters, 3 specific rabbit and small animal societies/charities, 3 Humane Societies, and anywhere between 6 and 20 other groups whose work has supported rabbit welfare or rescue initiatives, or have worked on issues that involve rabbits, including Animal Advocates Society, Action for Animals in Distress, Fur Bearer Defenders, the Kensington Foundation, the Pacific Animal Foundation, Pets in Need, the Vancouver Foundation and others. An educationally based program to deal with the issue of feral rabbits in park lands in the Gulf Islands has already been supported by the work of the Shell Environmental Fund. 

Larger groups like the SPCA and Humane Societies occupy a more ambiguous place in animal welfare and control measures. SPCAs as well as other “shelters” are, in our observations, not set up to adequately care for the existing large number of rabbits and small animals that are homeless or routinely given up. For example, the Vancouver SPCA – the one that takes the largest number of rabbits of all the SPCA branches – has only one small room allotted to rabbits and pocket pets alike, and no dedicated exercise run space for rabbits.  A number of the cages are of limited size and are unsuitable, even as temporary habitation.  

Situations at other branches are worse, and yet the numbers of rabbits and other animals relinquished on a daily basis continues.  Certainly we have heard of times when some SPCAs practice limited surrender i.e. they will state to members of then public who have the forethought to ask about bringing in a rabbit for surrender that there is no room. Larger branches will also refer individuals to smaller independent and volunteer-run rescue groups, which in turn are “overstressed” with a wide assortment of rabbits awaiting good homes.       

In BC, SPCAs and Humane Societies also bear a burden of animal control work including the capture of loose animals, in addition to being responsible for animal cruelty investigations. The tensions between animal welfare and animal control approaches are by now well documented so we will not dwell on them here. However, until and unless the situation changes it seems inevitable that some part of the costs for these activities will be paid for by municipalities through animal control and disposal contracts with these larger organizations.  

Animal control beyond lethal measures: changing public solutions 

Municipalities, then, directly bear the burden of large scale animal control measures because they are the ones who tend to pay for large scale animal control initiatives. In turn, animal control measures usually involve lethal solutions (shooting feral dogs for example, poisoning rats, or trapping urban wildlife) that are condemned by members of the public, in part due to changing public perceptions around animal welfare. 

A recent British study on grey squirrels that has applications here indicated that when surveyed most respondents preferred non-lethal methods of “pest control” over other alternatives (“Valuation of Immunocontraception as a Publicly Acceptable Form of Vertebrate Pest Species Control: The Introduced Grey Squirrel in Britain as an Example.” Http://www.ncl.ac.uk/clsm/people/mark_shirley/squirrels%) As the authors note, control of pest species is an emotive issue. However, their results indicated a favourable response toward the use of immunocontraceptive approaches to pest control from a variety of interest groups, as it was perceived as both effective and humane  

One local example of a feral rabbit situation and of the negative publicity that lethal solutions generate is the well known attempt by Victoria Hospital to rid itself of a “feral rabbit” problem by hiring people to shoot the rabbits. This case was widely reported in BC and beyond, and public pressure at least allowed for time to mount an attempt to rescue and then rehabilitate these rabbits. Similar issues with feral rabbits have been reported throughout the Pacific Northwest, including cases in California, Oregon and Washington, as well as Alaska. 

Even countries where rabbits have caused large scale problems, such as Australia, funding and solutions are moving toward more humane methods of control of rabbit populations including research on various forms of immunocontraception delivered either through an engineered myxoma virus or in feed. (See, for example, “Plants that make rabbits sterile.” HTTP://wwwcomm.murdoch.edu.au/synergy/0303/rabbits.html, Virus could sterilise Australia’s rabbits.” HTTP://www.newscientist.com/article.ns?id=dn2647 ). Work on immunocontraception is also being supplemented by research into other non-lethal forms of rabbit control including the development of repellents and visual scaring devices (See for example the UK’s DEFRA final project reports for project codes VCO414 and VCO218. The total project costs for these two projects were close to 1/2 million pounds sterling) 

Perhaps these changes have been fuelled by the growing awareness, particularly among groups that deal with feral colonies of former domesticated pets, that lethal control measures are ineffective where the root problem is not animals but humans dumping animals. In many circumstances, the quick fix promise offered by lethal solutions prove ineffective as many feral colonies are also opportunisitic: when populations are removed, other animals move to take over territory, or fresh animals are dumped at sites. Effective solutions to animal welfare and animal control problems are moving toward an enhanced focus on public education and a parallel move away from lethal solutions, in large part as a response to public pressure. 

Animal welfare paradigms: changing public perceptions 

The past 30 years have seen a slow paradigm shift toward improved animal welfare standards for all animals, including farmed animals, zoo animals, experimental and companion animals, and rabbits fall into most of these categories Both proposals for improvement and the specific implementation of improvements have been diverse, ranging from such things as  

 UBC’s Animal Welfare Program submission on Bill C51 which references treatment    

 of cephalopods such as squid and octopi  

 European and Canadian foci on certified ethically farmed (meat) animals

 anti-tethering recommendations for companion dogs implemented in Vancouver

 and improved standards for the treatment of experimental animals including the          

             EECs moratorium on the use of some Draize eye testing  

Additional emphasis has been placed on the psychological well-being of animals. Psychological factors now form part of considerations provided by shelters in their assessment of the companion animals that pass through their facilities, and there have been a number of studies on the minimalization of stress factors for meat, research/lab and companion animals. For example the work of Temple Grandin on minimalizing stressors for slaughterhouse beef is well known.  More locally Nadine Gourkouw’s (BC SPCA) studies back up other model programs whereby the provision of “houses” or safe spots in cat caging for surrendered cats improved “shelter” adjustment time.  This would naturally apply to rabbits as well as they are a prey animal with a well-developed sense of flight.  Such housing is commonly used by rabbit rescue/welfare organizations and the District of North Vancouver’s animal shelter.          

The growing interest in animal welfare and rights is further reflected in the fact that animal rights issues form a common part of philosophy curricula at the post secondary level, and that animal rights law is taught in many law faculties across the world. Certainly interest in animals rights is indicated when groups such as the University of Victoria Student Law Society organize a forum on animal rights and when Canadian Law faculty indicate animal rights as part of their specified areas of interest.  

This paradigm shift is equally reflected in the language we use to discuss those animals we share time and space with. For example, the phrase “companion animal” is replacing use of the term “pet”. In turn this can be argued to indicate a slow progress toward the replacement of notions of “pet ownership” with those of “(companion) animal guardianship” with its concomitant acknowledgement of a benign stewardship in relations with all animals. 

Rabbits and broad welfare issues 

Within this diverse spectrum of animal welfare activities, rabbits occupy a unique niche as the only common pet in the West it is culturally acceptable to eat (this is not to say that no other people keep as pets animals that might also be eaten). Having said this, we would like to point out that there are in fact no laws against eating your cat or dog and in fact there was a recent cruelty case in Eastern Canada that was based on someone cooking and apparently consuming a pet cat. 

Broad welfare initiatives for companion rabbits and an increasing awareness of the millions of rabbits kept as household “pets” have spurred an increasing focus on welfare issues directed toward rabbits and have certainly shifted rabbits toward the privileged category of companion animal we do not eat. Groups such as the Animal Welfare Institute cite a growing list of research done on welfare issues like group housing and environmental enrichment, the House Rabbit Society has drawn attention to the similarities between puppy and rabbit mills in discussing rabbits and the pet store industry, and decreasing numbers of rabbits are being used as experimental animals in Canada, with CCAC statistics indicating that approximately 14,000 rabbits were used for experimental purposes across Western Canada. Similarly, local statistics on the numbers of rabbits farmed in BC indicate an overall decline in the BC meat rabbit industry. 

Local and international press regularly carry stories about rabbits, including the plight of dumped domestic rabbits and ferals, and cruelty to rabbit cases. There have been several instances in the past couple of years where the University of Victoria has received mention as a site of instances of rabbit cruelty, and other local press coverage has discussed the plight of Jericho Beach bunnies. In turn the relatively recent Animal Cruelty web site (http://www.Pet-Abuse.Com) lists numerous instances both in the US and internationally of rabbit abuse cases, the majority of which deal with neglect and abandonment, although the vast majority of Canadian rabbit cruelty cases are not listed on this site. In brief, there are an increasing number of groups now turning their attention to rabbit welfare issues.  

Animal welfare issues and local politics 

More recently there have been a number of submissions to city councils on the issue or issues of animal welfare in the municipalities. For example, in 2004 the Vancouver Humane Society submitted a report to Vancouver City Council on enhanced animals’ welfare legislation in BC that covered a diverse range of issues including the sale of exotics, pet store legislation, urban trapping, and pet overpopulation.  The recent coverage of the Cloverdale rodeo was also presented within an animal welfare paradigm. The Lower Mainland houses many of BC’s 130-140 registered charities that deal with animal welfare, advocacy and conservancy issues, as well as many additional provincially registered non-profit societies and other less formal or not specifically Canadian groups, such as PETA.

These signs indicate animal welfare continues to be a topic for both local and provincial politics and that rabbit welfare is becoming more prominent as rabbits become better known as companion animals, better understood and cared for through ongoing research into rabbit welfare and health, and as their treatment as public pests in some parts of the world comes under public scrutiny and trends toward humane versus lethal pest solution. 

While these broad issues may seem at first distant from the minutiae of bylaw provision governing the treatment and sale of live animals from pet establishments, we suggest the unevenly drafted and applied levels of specification provided in bylaws, with additional guarantees placed around the health and well being of puppies and kittens but not rabbits or small animals is logically confusing and in need of timely amendment. Such amendments would be congruent with the increased acceptance of rabbits as companion animals on a par with dogs and cats, and with the growing awareness that many of the conditions that affect the sale of puppies and kittens also affect those of rabbit kits. Amending bylaws to specify levels of care for rabbits would enhance overall welfare standards for pet livestock, would provide additional protection for consumers, and would be a proactive step in the acknowledgement that animal welfare is an issue of public concern.

Last month the North Vancouver Chamber of Commerce presented the 2005 Best Business Award to Natural-Plus Pet Supplies, a successful business of 10 plus years that does not sell live product.  Instead, the owner and staff have focused on “innovative pet health trends” and have “aided in educating the community on the latest nutrition, alternative health care and pet behaviour.”  This is an example of the older style pet livestock business being replaced, due in large part, to public awareness and demand of a more progressive and enlightened animal welfare orientated industry.   

Read more on our Pet Shops & Rabbit Legislation page