Consultation on potential controls or prohibition of electronic training aids

Use and financial impact

Pet owners

Questions 10 to 19 sought information to help inform any decisions on business and regulatory impact that may be required. Questions 10- 12 were targeted specifically at pet owners but respondents within other respondent categories also tended to answer the questions. The analysis presented here includes all information provided.

Question 10: Have you ever bought an electronic training device? If yes, please specify which device(s) you have purchased.

Overall, 520 respondents reported that they had bought an electronic training device. However, not all of these respondents provided further information about the type of device(s) bought. Equally, a small number of respondents who had not answered the initial question at Question 10 did provide further information.

Information provided elsewhere, and particularly at Question 2, suggests that many of the devices being used have more than one function. In particular, there were references to remote training collars with a static pulse but also a vibration and/or sonic setting. Some boundary fence system users and suppliers referenced a sonic or vibration 'first warning' as an animal approached the fence, followed by a static pulse if the animal attempted to cross the fence.

Table 11 presents summary data based on types of device selected at Question 10. The analysis assumes that respondents may have selected the functions available through devices which they have purchased - for example that if someone has bought a device which had both a static pulse and a vibrate setting they may have checked both functions when completing their consultation response. Equally, the information available does not identify whether more than one device may have been bought. The summary figures below represent the number of respondents who reported at least one purchase of a device of that type and which performs that function. Percentages below are calculated against total number of respondents (n=1,032) and full results (by respondent category) are included within Annex 4 to this report.

Table 11: Question 10 - Reported incidences of purchasing, type of device by function

Type of device	Remote training collar		Anti-bark collar		Boundary Fence Systems
	N	%	N	%	N	%
Static pulse	362	35%	70	7%	132	13%
Spray	52	5%	61	6%
Sonic	103	10%	31	3%
Vibration	198	19%	47	5%

Around 1 in 3 respondents (35%) reported that they had bought a static pulse remote training collar. Around 1 in 5 (19%) had bought a vibration remote training collar. More respondents had bought remote training than anti-bark collars with the exception of spray collars. Around 1 in 8 respondents had bought a boundary fence system.

Question 11: From where did you purchase your device?

Overall, 536 respondents provided information at Question 11. Respondents were only able to select one option. However, in their other comments a small number of respondents noted additional routes through which they had made purchases. In total, 557 purchases were reported.

The summary figures below represent the number of respondents who reported having made at least one purchase through each route. Percentages below are calculated against the total number of respondents who reported any purchase (n=536) and full results (by respondent category) are included within Annex 4 to this report.

Table 12: Question 11 - Purchase route

Purchase route	N	% of respondents who had purchased a device
Direct from a manufacturer	317	59%
Online e.g. Amazon/eBay	112	21%
Animal trainer or behaviourist	52	10%
Pet store	33	6%
Distributor (for a manufacturer)	17	3%
Other (not known)	13	2%
Other retailer e.g. countryside sports shop	7	1%
Online specialist retailer (other than manufacturer)	4	1%
Veterinary practice	2	<1%
TOTAL	557

Percentages do not sum to 100% due to rounding

The majority of those who had purchased an electronic training aid had purchased a device from the manufacturer (around 2 in 3 or 59%). Around 1 in 5 (21%) had purchased a device through a general online retailer. Although not one of the provided options, around 1 in 10 (10%) reported that they had bought a device from an animal trainer or behaviourist.

Question 12: How much did your device cost?

Overall, 532 respondents provided information about the cost of devices they had purchased at Question 12. Respondents were only able to select one option. The percentages below are based on the number of respondents answering this question (n=532). Summary results are presented below and full results (by respondent category) are included within Annex 4 to this report.

Table 13: Question 12 - Cost of device

Cost	N	%
Under £50	46	9%
£50-£100	97	19%
£100-150	123	23%
Over £150	209	39%
Don't know/can't remember	57	11%
TOTAL	532	100%

Percentages do not sum to 100% due to rounding

Of the 532 respondents answering this question, the highest proportion (39%) reported having purchased a device which cost over £150, while 23% reported having purchased a device costing between £100-150. In the lower price brackets, 19% reported having spent between £50-100 and 9% under £50.

Other points to note are:

• There is a correlation between having bought a more expensive device and having bought a boundary fence system - 39% of those who reported spending over £150 had reported buying a boundary fence system. However, only 25% of those who had bought a device reported buying a boundary fence system.
• There was also a correlation between having paid under £50 for a device and having purchased online from a site such as Amazon or eBay - 21% of devices were purchased online but 70% of those spending under £50 had used this online purchase route.

Manufacturers/retailers

Questions 13 to 15 were targeted at manufacturers and retailers and sought information on how introducing any ban or regulations might affect their business in the electronic training device industry. However, respondents across the different respondent categories sometimes answered this question. The analysis presented here has been restricted to answers given by respondents in categories in which respondents are most likely to have a relevant business interest: animal behaviourists, animal care respondents, animal trainers, pet supplies respondents, veterinary profession respondents and owner of working dogs respondents.

Question 13: Would your business/company be affected by any ban or stricter regulations put on the use in Scotland of any electronic training aids listed?

Question 13 asked respondents whether their business would be affected by any ban or stricter regulations put in place. Summary results are set out in Table 14 below and full results are included within Annex 4 to this report.

Table 14: Question 13 - responses by device type

Type of device	Yes		No		Don't know		ALL
	N	%	N	%	N	%	N	%
Remote training collar
Static pulse	59	31%	116	61%	15	8%	190	100%
Spray	17	10%	130	80%	16	10%	163	100%
Sonic	24	14%	128	77%	14	8%	166	100%
Vibration	45	25%	116	66%	16	9%	177	100%
Anti-bark collar
Static pulse	37	21%	129	72%	13	7%	179	100%
Spray	15	9%	131	82%	14	9%	160	100%
Sonic	14	9%	133	83%	14	9%	161	100%
Vibration	27	16%	126	76%	12	7%	165	100%
Boundary fence system	28	16%	131	77%	12	7%	171	100%

Percentages may not sum to 100% due to rounding

For all devices, a majority of those answering the question answered that a ban or stricter regulations would not affect their business. Amongst those who did think their business would be affected, the highest proportion of respondents (31%) thought they would be affected by a ban or stricter regulations on remote training static pulse collars, followed by remote training vibration collars.

A total of 84 respondents went on to make a comment. Taking their answer on static pulse remote training collars as an indicator, 44 said their business would be affected, 27 said it would not be affected, 9 did not know and 4 had not answered that question.

The most frequently identified possible effect was dealing with fewer animal suffering from the negative effects of having been trained with an electronic training aid. This group of respondents included those who had answered 'Yes', 'No' and 'Don't know' at Question 13 and included animal behaviourists, animal trainers and a veterinary profession respondent. Many of these respondents stressed that they would be delighted to see any reduction in business which results from banning or regulating electronic training aids.

Otherwise, the most frequently identified effect was that some dogs would be more difficult or even impossible to train - animal trainers and owner of working dog respondents raised this issue. Other effects identified included:

• A loss of sales. This was an issue raised by pet supplies and animal trainer respondents. A supplier of boundary fence systems was amongst these respondents and reported that any ban on boundary fences would have a very serious effect on their business in Scotland.
• That any ban in Scotland could ultimately make a ban in other countries more likely and hence could have a negative impact on businesses operating outwith Scotland in the longer term.
• An increase in the number of dogs being trained using reward-based techniques. This was identified by a small group of animal behaviourists and animal trainers. There were also occasional references to turning away clients who insist on using electronic collars.

Those who tended to answer that their business would not be affected or who did not know sometimes noted that they did not operate in Scotland. Otherwise, a number of trainers or behaviourists did suggest that either the number of dogs they work with and/or the types of issues dogs have could change. Most frequently, they reported that they could see a welcome decrease in the number of dogs being brought to them because they had been damaged through the use of electronic training aids.

Question 14: If known, how many listed electronic training aids has your business sold to users in Scotland within the 2014/15 financial year?

Question 15: If known, please provide an approximate annual profit obtained from sales of electronic training devices per year. If possible, please indicate what proportion of those sales were in Scotland or the UK.

Only 15 respondents provided relevant information at one or both of Questions 14 and 15. However, 2 of these respondents did not wish their response to be published and the information provided is not included in the analysis below. The remaining 13 respondents were made up of 8 animal trainers, 3 animal behaviourists and 2 pet supplies respondents. Six respondents were based in the USA, 3 in England, and one each in Scotland, the Republic of Ireland, Canada and Australia.

In terms of the number of aids sold to users in Scotland and the country in which the provider is based (in brackets):

• Five respondents reported having sold remote training static pulse collars. Numbers sold were: 500+ ( USA), 200 (England), 8 (England), 5 (Scotland) and 2 ( USA).
• Three respondents reported having sold remote training vibration collars. Numbers sold were: 5 (Scotland), 1 (England) and 1 ( USA).
• Three respondents reported having sold anti-bark, static pulse collars. Numbers sold were: 50 (England), 5 (England) and 3 ( USA).
• One respondent reported having sold anti-bark, vibration collars. Numbers sold were: 3 ( USA).
• Four respondents reported having sold boundary fence systems. Number sold were: 60 (England), 52 (England), 10 (England) and 4 ( USA).

Ten respondents provided some information around the approximate annual profit, although it was not always clear whether or how this profit related to any sales in Scotland. The information provided included

• Four USA-based respondents reported having made a profit in the USA (ranging from $250-$40,000) but having made no sales in Scotland. An Australia-based company reported a profit of AUD$8,000 but no sales in Scotland.
• A Canada-based respondent reported a profit of $500,000+ of which around 20% may have come from UK, including Scottish, sales. A USA-based respondent reported a profit of $900. This company had also reported sales in Scotland.
• The Scotland-based respondent who had reported sales in Scotland also reported a £100 profit.
• An England-based respondent reported that their company had not made a profit in that year because it had been sold, and another reported that their company was going through a managed decline but had made a £5,000 profit. Both of these respondents had reported sales in Scotland.

Dog trainers/behaviourists/manufacturers/retailers

Questions 16 and 17 were addressed to dog trainers, behaviourists, manufacturers and retailers. As at Questions 13 to 15, respondents across the different respondent categories sometimes answered this question. The analysis presented here has been restricted to answers given by respondents in categories in which respondents are most likely to have a relevant business interest: animal behaviourists, animal care respondents, animal trainers, pet supplies respondents, veterinary profession respondents and owner of working dogs respondents.

Question 16 asked respondents whether a ban or restriction in Scotland on the use of any of the electronic training aids listed would have an effect on their business or organisation. Summary results are set out in Table 15 below. Full results, by respondent category, are set out within Annex 4 to this report. Percentages are calculated against the number of respondents at each question.

Question 16: Would a ban or restriction in Scotland on the use of any of the electronic training aids listed have an effect on your business or organisation?

Table 15: Question 16 - responses by device type

Type of device	Yes		No		Don't know		ALL
	N	%	N	%	N	%	N	%
Remote training collar
Static pulse	54	29%	122	65%	13	7%	189	100%
Spray	20	12%	131	79%	14	8%	165	100%
Sonic	27	16%	130	77%	12	7%	169	100%
Vibration	39	22%	125	71%	12	7%	176	100%
Anti-bark collar
Static pulse	34	19%	130	74%	12	7%	176	100%
Spray	19	12%	131	80%	14	9%	164	100%
Sonic	20	12%	130	80%	13	8%	163	100%
Vibration	26	16%	125	76%	14	8%	165	100%
Boundary fence system	26	15%	132	77%	13	8%	171	100%

Percentages may not sum to 100% due to rounding

The results at Question 16 are broadly in line with those at Question 13 and for all devices, a majority of those answering the question answered that a ban or stricter regulations would not affect their business. Amongst those who did think their business would be affected, the highest proportion of respondents (29%) thought they would be affected by a ban or stricter regulations on the use of remote training static pulse collars, followed by remote training vibration collars (22%).

A total of 68 respondents went on to make a comment, although many either referred back or made a similar comment as at Question 13. Additional issues raised at Question 16 included:

• An animal trainer organisation which operates in Wales reported that their organisation does not allow the use of static pulse or boundary collars under any circumstances and that the banning of static pulse collars in Wales has had no negative impact.
• An owner of working dogs respondent was concerned about the effects of uncontrollable dogs worrying ewes around lambing time and lambs being aborted or injured ewes needing to be culled. They suggested that responsible dog owners would rather their dogs were contained or trained than risk the possible shooting of their pets if they were involved in such an incident.

Question 17: Please describe what effect restricting the use of electronic collars to authorised persons would have on your business or organisation?

A total of 101 respondents made a comment. Question 17 focused on the effect of restricting the use of electronic collars (as opposed to a ban or stricter regulations). However, many respondents did refer back to previous comments (at Questions 13 or 16) and many of the issues raised were broadly the same as at earlier questions.

Around 1 in 3 suggested that restricting the use of electronic collars would have no effect on their organisation. This included a small number who noted that they would not seek authorisation to use electronic collars. Many of the other issues raised were also similar to those raised around a ban and regulations, including that there would be fewer traumatised dogs to deal with, or that some dogs would be harder to train and, if they could not be trained, that euthanasia might be the only option. A small number of respondents also pointed to possible loss of sales and one to a very significant and damaging loss of sales.

Issues raised which clearly focused on the possible effect of regulations were that:

• The nature and extent of any effect would depend on the detail of the authorisation process and in particular on whether those wishing to use or train others in the use of electronic training aids are able to become authorised.
• The authorisation process could be time consuming.
• If authorisation was restricted to qualified or certified trainers or behaviourists it would most likely lead to increased business for this group, especially if devices could not be purchased online or at a pet store and without proper training.
• Any restrictions could make electronic training aids seem like an inherently dangerous tool and fewer people may choose to use them - this could then have a knock-on effect on those supplying devices or who train others to use them.
• It can already be difficult to find trainers able to offer training on using electronic training aids, especially in more remote areas. Restrictions would be likely to make this even more difficult and by extension could impact on the number of devices sold.

Pet behaviourists / pet trainers

The final two main consultation questions were aimed at animal behaviourists and trainers. As at other use and financial impact questions, the analysis presented here draws on answers provided by animal behaviourists, animal care respondents, animal trainers, pet supplies respondents, veterinary profession respondents and owner of working dogs respondents.

Question 18: Approximately how many dogs did you recommend the use of electronic training collars for in Scotland in 2014?

A breakdown of the responses given by the 140 respondents who answered this question is set out both in Table 16 below and in the subsequent text.

Table 16: Question 18 - Number of dogs for which electronic training collars were recommended in Scotland

Number of dogs	Number of respondents
0*	122
1-5	11
6-15	4
30	1
TOTAL	138

* This includes a small number of respondents who reported recommending the use of collars but for dogs in other countries.

In addition, a pet supplies respondent reported that there were 52 pets on their system in Scotland at the time and another respondent reported having made recommendations concerning high hundreds if not thousands of dogs.

Question 19: If you sometimes recommend the use of an electronic training collar, generally, do you provide the electronic training collars or do owners purchase the collars themselves?

A total of 74 respondents provided information about how collars are generally acquired if they have recommended their use. Those answering this question included a number who had not answered the previous question or who had reported making no recommendations of use in Scotland in 2014. A breakdown of responses is set out in Table 17 below.

Table 17: Question 19 - Route through which recommended collars are acquired

Route	Number of respondents
I provide the collar	32
Owners purchase themselves	24
It varies	18
TOTAL	74

The largest proportion of respondents - around 2 in 5 - reported providing the collar themselves while around 1 in 4 said that it varies. The remaining respondents reported that owners purchased the collars themselves.

Question 20: Please provide any other comments you may wish to add on a potential ban or regulation of electronic training devices.

At the final main consultation question respondents were asked to provide any other comments they wished to add on a potential ban or further regulation. A total of 550 respondents went on to comment. The majority of these comments referred back to, summarised, expanded on or restated one of two broader positions on this issue. These two positions can be summarised as follows.

• Electronic training aids are effective training devices which, far from threatening the welfare of animals, can allow them to lead healthy and happy lives. This can be evidenced by the numerous animals who might otherwise have been confined to the home or for which euthanasia might have been the only alternative had behavioural issues not been addressed. There are some types of dogs, such as working dogs, for which electronic training aids offer particular benefits. Boundary containment fences have kept both cats and dogs safe and able to access the outdoors. Any changes required should focus on further education rather than a ban or stricter regulations.
• Electronic training aids, and static pulse devices in particular, are harmful to the welfare of animals if not cruel. The harm they do can be both physiological and psychological and may include causing extreme stress and anxiety, repression of aggression or causing an animal to 'shut down'. There are far more humane and more effective methods for training animals based on positive reinforcement. There is a substantial body of evidence which sets out the advantages of positive approaches, or which points to the harmful effects of electronic training aid-based approaches. A ban would be the only or the most effective way to protect animals.

There was also a small number of respondents who submitted extensive additional comments, either at Question 20 or as a statement submitted outwith the Scottish Government's online consultation hub. In particular, two respondents, (the Electronic Collar Manufacturer's Association ( ECMA) and a team which carries out research into electronic training aids from the University of Lincoln), submitted substantive additional comments. Both of these respondents agreed to their response being published and along with all other published responses they can be accessed on the Scottish Government's website.

In summary, points highlighted by the research team from the University of Lincoln included that:

• They are the lead researchers on two Defra-funded research projects looking at electronic training aids, are the authors of the Companion Animal Welfare Council's Report referenced in the consultation paper, and have also led a study on the impact of electric boundary systems on the welfare of cats. The findings of the recent research are yet to be published.
• There are important scientific and technical distinctions to be made between remote training collars, anti-barking collars and electric boundary systems and each needs to be considered separately.
• Remote training collars: Further work undertaken since the Defra-funded studies were completed has been published in a PLOS ONE paper (see Annex 3 for full reference). This work suggested stronger evidence of suffering during training than was reported during the Defra-funded study ^[7] . It also produced evidence of poor timing in the use of devices, even by professional trainers. The team is of the view that, given their findings that the collars appeared to produce no added benefit but posed a greater risk, a total ban or at the very least tight regulation of remote, owner operated or hand held electronic training collars is justified.
• Anti-barking collars: There is very limited research available on the welfare impact of anti-bark collars and further research is required. Vibration collars may be considered to pose the lowest risk and may have value, especially with deaf dogs. By contrast there are grounds for concern about the aversiveness of other anti-bark collars, and the team consider that closer regulation or a total ban is warranted. If they are not to be banned, the inclusion of technical and safety features (as currently supported by the ECMA) for remote training collars is considered essential.
• Electric boundary systems: from an animal welfare perspective, there are solid grounds to differentiate remote collar training systems that at depend on a human operator and boundary systems. Given the known risk of cats straying onto roads and the limitations of alternative approaches to preventing that happening, the team believe that the evidence does not support a complete ban. However, they would support regulation to ensure best practice guidelines are followed.

Issues highlighted within the ECMA's response have been set out elsewhere within the analysis (for example at Questions 2 and 5). They highlighted that all three of the current groups of devices are consistent with the legal obligations and potential liabilities to dog owners in Scotland. The ECMA also:

• Suggested that there is considerable evidence substantiating the demand to retain these options for dog owners in Scotland.
• Suggested that there is much highly subjective and ill-informed opinion and hearsay which does not recognise the technical capabilities and safety of the latest generation of quality modern-day electronic collar products.
• Concluded that a legislative ban would create a problem for all those involved and would be counterintuitive to the well-being of dogs.
• Noted their commitment to assisting people in responsible care of their dogs and cats and to collaborate with government and wider stakeholders. They noted that ECMA has published materials outlining when it is appropriate to use electronic training aids and how to use them in a way that is safe, supervised and effective.

Finally, a number of other respondents raised issues at Question 20 which have not been covered elsewhere within this report. These included that:

• The consultation document or questions appear to overlook key issues or to be slanted in favour of a preferred outcome. This was suggested both by those calling for or arguing against a ban or stricter regulations. Respondents were asked for feedback on the consultation process and summary results from these question ( Questions 21- 23) are set out within Annex 5.
• The use of electronic training aids is an ethical issue and any policy decisions should not be driven by financial considerations. An associated point was that the increasing number of other countries that have introduced bans or regulation should not be discounted.
• Public opinion - as evidenced by a Kennel Club commissioned survey - would support a ban of static pulse collars.
• There are other tools available - including prong collars for dogs and electric fencing for livestock which represent an equivalent or greater threat to the welfare of animals than do electronic training aids. It is not clear why the Scottish Government would consider action around electronic training aids if they do not see the need to take action against these other types of device.
• Some of the most highly trained dogs in the world (including Police and Military dogs) are trained without the use of electronic training aids.
• E collars may enable people who would otherwise lack the strength or stamina to keep a harder-to-train dog.
• Any regulation or other control would be better left to local authorities. This would at least allow for the varied circumstances across Scotland to be taken into account - for example the difference between working with a dog at distance in a rural area and controlling the behaviour of a dog being walked in an urban environment.