{This article applies to anyone who is subject to either, Zoo licencing, Animal Activities Licencing, or is subject to another Continuing Professional Development Framework. The examples and excerpts below are taken from the Animal Activities Licencing Regulations, but the principles and obligations are the same across all professionals working with birds of prey}
The Animal Activities Licencing regime came into law in April 2018, with first licences being issued from the late autumn of that year. Local inspectors tended to take a ‘light touch’ approach with those early applications, but we hear of tighter and more rigorous inspections now as licenses are renewed and new licences granted.
One specific area of concern is what the Law says about staff training and development, and the general lack of knowledge amongst licensees about what they are obliged to do. This article discusses your legal requirements and ways in which you can most easily meet your obligations.
{Note: The examples used are taken from the Animal Activities Licensing Regulations, but apply equally to holders of Zoo Licences as well. The article is also of interest to others who may need to demonstrate on-going training and development for any other occupation involving birds of prey.}
Remember that failure to meet the conditions of your licence may result in a costly suspension of your activities and additional re-inspection fees.
What does the Law say? (the highlights are mine – Ed.)
Staffing
4.—(1) Sufficient numbers of people who are competent for the purpose must be available to provide a level of care that ensures that the welfare needs of all the animals are met.
(2) The licence holder or a designated manager and any staff employed to care for the animals must have competence to identify the normal behaviour of the species for which they are caring and to recognise signs of, and take appropriate measures to mitigate or prevent, pain, suffering, injury, disease or abnormal behaviour.
(3) The licence holder must provide and ensure the implementation of a written training policy for all staff.
The Legislation also says that:
“A local authority may grant or renew a licence ………having regard to such guidance as may be issued by the Secretary of State…“
Source: The Animal Welfare (Licensing of Activities Involving Animals) (England) Regulations 2018
The Guidance:
It is clear from the two extracts from the legislation that all AAL licence holders have obligations regarding themselves and their staff, but what exactly are they?
Let’s see what ‘Guidance’ the Local Authority Inspectors have been given. Please note that these guidance notes have the same weight as the legislation, and are not ‘optional’ in any sense.
Records:
“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”.
This means that you must be able to produce ‘on-demand’ and on the day of inspections all records including your records and policy documents regarding staff training. If you were asked for these now, today, could you produce them?
Staffing:
“No animal must be kept for exhibition or exhibited unless staff on duty are competent in their care and welfare”.
“Staff must either:
- have a recognisable qualification
- show they have relevant and sufficient knowledge and experience, for example, working on a film set or mobile animal exhibit”
In particular, Local Authority Inspectors are instructed to look at:
..”training records as evidence of suitable induction training of staff in:
- animal welfare, including recognising poor welfare
- animal handling
- animal behaviour
- cleanliness and hygiene
- feeding and food preparation
- disease prevention and control
- recognition and first aid treatment of sick or injured animals
“The staff training policy must be reviewed and updated each year.
It must include:
- an annual appraisal
- planned and continued professional development
- recognition of knowledge gaps
This applies to all staff including the licence holder.
Training can be demonstrated by:
- knowledge of research and developments for specific species
- engagement with online courses
- annual appraisal documents
Evidence of staff attendance or completion of the training must be provided.
Read enough yet? Register for free access to our guides and other documents, or read on for more information…..
Surely this is an unacceptable burden to place on small businesses:
Yes we at the IRBPP agree. Most professionals working with birds of prey are small businesses. They don’t have HR departments, they have little or no formal qualifications and they have little or no expertise in staff training, CPD (continuous personal development), or the kind of detailed record-keeping needed.
Is the IRBPP doing anything to help?
YES! To further support all professionals working with birds of prey we have developed simple ways to help you meet your obligations in a simple, easy to use manner and it’s totally free to join.
Did you realise that simply by reading this article you have already undertaken some CPD? Easy isn’t it. However, can you show that it’s meeting a pre-identified training need (as identified by an appraisal), and how are you going to record this activity, and how much CPD should you record.
Why don’t you let us help you.
Yes please, make my life simple:
Ok. Let’s take one step at a time. First join the IRBPP today. It’s totally free and will give you immediate access to your Free Member resource area. There’s no fee to join, no fee for your free membership and no obligation.
Once you have joined find your way to the Free Member resources area where we have further information on this topic, and a simple guide on Meeting your training obligations.
That’s it – couldn’t be simpler.