The Limitations of Finland's Current Sleddog Welfare Regulations

Finnish Law

In Finland, the Agriculture and Forestry Ministry is the ultimate authority in terms of the implementation of, and compliance with, the Animal Protection Act. The Food Safety Authority directs and supervises, and the Regional State Administrative Agency implements, within its territory .

The municipal health officer responsible for supervising and monitoring animal welfare law within a municipality, a designated veterinarian and an animal protection supervisor from the regional state administrative agency can all be involved in inspections. The inspector has the right to enter the premises where the animal is kept and audit both the animal and the animal's facilities and food preparation areas

Finland has, arguably, some of the toughest animal welfare legislation in the world and each farm is supposed to be assessed annually. However, when it comes down to what is best for the dogs on the sleddog farms, I am not entirely sure that the law is as applicable as it could be. According to Maneesha Deckha, an associate professor of law at the University of Victoria, animal protection laws worldwide tend to be narrow in scope and only protect certain animals from certain types of treatment that we, as a culture, find shocking.

Clearly from the law's perspective, despite there being literally thousands of dogs currently working in this industry, there is clearly nothing in particular that they need to be protected from, since they are simply classified as a general small animal under the law. In other words, the vet checks are carried out against the same set of criteria used to assess the care of small pets (including dogs, cats, rabits and other hobby animals including hunting dogs). Sleddogs moved into this category, in terms of vet 'checks' in the 2010 addendum to the animal welfare act.

Prior to this, they were assessed, rather, against general 'farm-animal' assessment standards. Some might argue that this is a move in a good direction in that farm animals are bred as commodities, and their ultimate aim is to enter the food chain. Hence, the 'when to kill' decision for them is a simple commercial equation.

In reality, however, the way in which sleddogs is kept is generally pretty different to how most pets are kept and, similarly, it is pretty different to the way in which most farm animals are kept. In other words, it is probably high time that there was legislation specific to this particularly important part of the northern economy.

When I discussed this recently with a vet, she pointed out that there is some incentive within the farming system (in the form of reduced price operations etc) for farms that go 'above and beyond' in terms of the treatments they offer to their livestock and that this incentive for high quality care doesn't apply to small animal pets. Moving sleddogs to the latter category, therefore, can have its own risks.

If, rather, sleddogs were seen positively within the farm animal category, veterinary support for 'above and beyond' treatments like, for instance, spaying females with frequently infected and non-responsive mammary discharges (to reduce their very high risk of mammary tumours), (or prior to adoption, to reduce the liklihood of further pregnancies) or for castrations for dogs with retained testicles (cryptochidism) to reduce their otherwise 70% liklihood of testicular cancer onset - or, indeed, for expensive eye drop treatments for dogs with Panus or glaucoma, which likely go untreated, at present, in many farms, maybe this would be a good thing? I am sure that the vets would have a better idea about the treatments which would be worthwhile incentivising but anyway, it was an interesting perspective.

(This also made me also think about the diagnostic limitations of where we live. When we started our farm, the nearest Xray facility was 300km away and therefore required a round-trip journey of almost an entire day, to get, for instance, a limp investigated in more depth. Whilst that may be relatively easily justifiable to a pet owner with just one dog, a farm with 150 times more need for diagnostic tools is going to have to limit the journey to the most extreme cases or they will spend an almost unjustifiable amount of time and money in diagnosing issues amongst some of their dogs at the potenital 'expense' of the rest. Now, the situation is better in that there is one Xray facility 200km south and another, 200km SE.

In other words, it only takes c. 5 - 6 hours to take a dog for Xray and back. However, it is still a huge and costly journey and farm owners have to factor those costs with the additional inherent risk of travelling 400km on icy roads in sub zero temperatures against the potential benefit to one dog, when making the decision as to whether to investigate the underlying issue causing a problem with the dog or just 'put it down' (or leave it untreated until the summer months when time is more readily available and the risk factor involved in driving, reduced). The equation may factor out more in the favour of the individual dog if one of the component parts (the cost of the procedure itself) was offset to a degree. Anyway, it is an interesting perspective to think about.

Current Veterinary Check Limitations: Judgement Calls - the challenge of the 'grey'

Clearly there are some obvious parameters which can be checked by visiting vets - for instance the number of dogs contained within a specific cage size or the length of chains to which dogs are attached. In reality, however, farms can simply claim that dogs are temporarily together with others or 'temporarily' on travel chains at the time of a check even if in reality the dogs may not move off small lengths of travel chains for months at a time. Who would be any wiser?

Similarly, if the check is carried out on a sunny day, the farm is going to look a lot more well drained than if the check is carried out in snow-melt season, and whilst the vets can compensate for conditions to a degree, depending on their level of experience (which also varies, a lot, vet by vet), the checking procedure is still a fairly challenging one for the vets.

And, even if it is clear that SOME huskies MAY need an isolated kennel and others, not, what IS an insulated kennel, (since the quality seems to vary so tremendously between the farms) and what degree of 'huskiness' does a husky need to have to NOT need an insulated kennel? etc.

The assumption - even between vets is that 'fluffy' dogs do not need insulated kennels. However, we have seen that the fluffiest of the arctic breeds that have come to us from farms without insulated kennels are vastly more prone to testicular and mammary frostbite than even short-haired alaskan breeds on our own farm who have lived in insulated kennels all their lives. Clearly once a dog gets frostbite once, it is, like humans, more susceptible to it in the future. Hence, some of the assumptions within the industry pertaining to the arctic breeds might actually need to be questioned!

Incidentally, the only research I have found on the subject of kennels used in sleddog centres in Scandinavia was by Julia Hofman, from Lunds University, Sweden, in 2014. Her dissertation is available here

Similarly, what constitutes 'exercise frequently' in terms of summer months, and how can a farm show this / can a vet really check it? etc. Most vets are aware, for instance, that very few sleddogs are handled or socialised a great deal in the summer months - but how can they prove or disprove that and what would that warrent, in terms of discipline towards the owners, if it needed to be addressed? At best, the vets are probably able to hazard a 'best guess' based on what they know of the owners and how many people work in the farm in the summer. But essentially, they can't really know, even if they want to go the extra mile and really do so.

In a similar vein, many dog farms have dogs which essentially spend their entire winters running multiday safaris, travelling from wilderness cabin to wilderness cabin where they sleep attached to short travel chains and predominately without kennels, along the way. Hence for these dogs it is pretty much irrelevant how well the farm kennels and chains meet the requirements of the law, since this is not where the dogs are living in the most challenging season. And yet it is fairly impractical to expect vets to travel out to check for conditions in wilderness cabins so the arguably 'most harsh' living conditions for the dogs are therefore seldom taken into account during checks.

Essentially, therefore, it would not be unjustifiable to question the usefulness of the current recommendations in terms of really assessing whether or not sleddogs live a healthy and stimulated / happy life vs a fairly miserable and unsocialised one.

State of living vs state of dying

More importantly, when it comes to owners choosing whether to treat illnesses or injuries or simply shoot / put the dogs down to save expense, the 'law' is that it is totally at the discretion of the owners. I believe that this is actually a far bigger issue for husky farms than whether or not, for example, the dogs are being kept on chain of exactly 3.6m, or not.

Of course, if we think of dogs in the same way as we do the animals feeding the human food chain (cows, sheep, pigs etc), clearly it is considered totally acceptable, by most of society, for farmers to simply shoot any animal for which the cost of treatment when injured or unhealthy (or old or not good gene-pool material etc), outweighs the monetary value of the animal. For many in the industry, sleddogs fall within this category of animal (despite them now being assessed more under the small animal legislation) and those who believe, as I do, that dogs are, and should be, in 'a bit of a different' category and should be treated more than as livestock commodities (eg considering the generations of effort that have gone into breeding for traits like sociability with humans), are considered naive.

It is definitely far from uncommon, for instance, for farms with some of the best names in the industry to purposefully breed annually with the aim of only keeping the cream of the crop and whilst this type of attitude is generally accepted as being OK, it will be interesting to see how long that status quo will be maintained as consumers become more knowledgable about the behind-the-scenes reality.

Regardless of the rights or wrongs of the situation it remains that all a vet can do, when checking the state of a farm, at present, is to check that the alive animals are in reasonably good nick. Clearly, since this is also in the best interest of the farm owners, this side of things is generally a lot less of a real issue than the end of life issues which are a far more difficult and emotive issue to address.

Supervisory Vets

One possible improvement that has come about recently in some regions, in terms of vet checks, is that there is a move towards there being a separate farm-health and welfare checking / supervisory vet from the 'treating' vets. The belief is that if a vet is more separate from the people that they are checking, they can maintain a little more distance from the people being assessed and can maybe speak more openly about any potential issues. The flip side, of course, is that they are less likely to really know the reality of the situation on the farm aside from during their annual spot checks, although I guess the thought is that that would at least confer with the treating vets and get their opinion about the real state of affairs.

Veterinary Check Limitations: Judgement Calls - the challenge of the 'black and white'

Having talked, above, about how vague many of the current guidelines are, and how much pressure that puts on checking vets to effectively make judgement calls, it is worth considering the fact that on the flip side, having very prescriptive 'black and white' laws can also result in a similar problem and that if folk are asked to adhere blindly to the letter of such a law, they may not end up adhering to its spirit.

Let me explain.

One thing that IS actually pretty clear within the legislation, for instance, is that when dogs are attached to chains, the chains should be over 3.6m in length. I would argue, however, that this is not always in the best interest of all sleddogs, all of the time. I think that the length is too long, for instance, for a) small female huskies (for whom it is too heavy), b) young dogs getting used to the chain for the first time at c. 1 year of age (who get tangled a lot less when trained, first, on a shorter chain) and c) for dogs recovering from eg limps or other leg injuries which should have their movement restricted to a degree for their own good.

For this reason, whilst we comply with the letter of the law on our farm, we only comply with its spirit of the law in our sick dog / chain-training area. Luckily, to date, the fact that we have shorter chains in this area, has not been a problem for visiting / checking vets who have understood- and even agreed with, the 'why'. However, by turning a blind eye and allowing us to effectively break the rule, we are on thin ice when it comes to the law (even if the dogs in this area are never here permanently).

We are then asking for that same grey judgement call that we were saying was problematic, above, to come into effect, here, when checked by vets. The box which needs to be 'ticked' is simply one showing 'compliance' or not.... (Interestingly, in this particular aspect we are not too worried, since our sick-dog area chains are the same length as they are in a farm which went to court for the right to have shorter chains (and won). Hence, a precedent for challenging this length actually exists.)

A similar point could be argued with the current EU transportation laws which apply equally to our dogs (which get transported in -30C) and to house pets being transported in +30C in Spain. Clearly, it is fairly unlikely that the laws are optimum for both and yet owners in both areas have to theoretically comply or be negligant (even if they honestly believe that the laws are not in the best interest of the dogs).

It seems to be a big challenge, therefore, to write legislation which is clear enough to not need to be interpreted by the individual inspector (eg w.r.t. the kennel suitability / insulation - which, in turn, is also dependent, to a degree, on the type of sleddog in question - and many farms have a mixture of dogs and move them around, to further complicate matters!) whilst also being specific enough to meet the actual needs of the industry being checked.

What happens NOW when a farm is found to be non-compliant?

Following checks with the current system, vets write an 'official paper' about their basic findings on the day of their visit and in this, they write recommendations for change, when necessary, and a timeline within which they would like the change to happen.

Unless the vet considers the issue to be a very black and white or extreme case, however, from my experience, they are unlikley to either recheck it again within the year, or to take further action. Hence, in most cases, the checking system to date hasn't seemed to result in any positive change.

NB: I say this with a little trepidation since I am sure that some vets have had some impact on some farms. However, I have yet to hear, for instance, of anyone in the industry talking about any criminal proceedings which have been started against a farm, and this is surprising since nearly anyone in the industry could name a handful of farms which fall woefully short of basic needs and clearly meet neither the spirit or the letter of even the existing laws. There is even one case in Finland in the last two years in which the conditions on a particular farm had become so well known that a number of people in the industry were raising concerns, but the local vet said that they couldn't really do anything about it.

The movement towards having supervisory 'checking' vets is maybe one step in the right direction in this regard. There has been a worry about the fact that, to date, it might have been hard for local area vets who are not experienced in carrying out checks to actually know, without many farms to compare to, if standards on a farm they are checking are above or below average. And then you introduce the risk of some good farms being held accountable for small issues which they need to improve upon whilst at the same time, some terrible farms are effectively free of restrictions.

Similarly, there has been the worry that local area vets might be hesitant to blow a relationship with a farm if they thought that there was a chance it would mean that the dogs would just be shot or left untreated post injury rather than being brought to them if there was conflict between the parties.

All of these issues have been further compounded by the fact that veterinary inspectors cannot fine the farm owners directly so their only option, should they choose to take action against a farm, is to take an issue to the police and effectively make it a criminal offence. This is a hard route for any vet to choose to go down whilst there are not really any well agreed standards within the veterinary community as to when 'enough is really enough' and what really constitutes something that fulfills the spirit of the law (eg what DOES 'insulated' mean in terms of kennels / what does 'exercise frequently' mean in terms of summer months etc).

But before we think that everything is doom and gloom, please remember that the quality of life for the majority of sleddogs is not too bad! And just as the 'bad' farms are common knowledge in the industry, so too are the good ones. And, whilst most might have widely differing ideas as to what constitutes a 5* performance in terms of sleddog welfare, (particularly w.r.t. end of life practices), everyone could no-doubt name 5 farms which they believe to be excellent in terms of sleddog welfare, in which the majority of dogs are probably looked after as well, or better, than the average small animal pet.

Other relevant legislation

Meanwhile, the links given here are to Finnish legislation which in some way pertains to the dog farms.

For instance, the Animal Feed Legislation, Animal Feed (linked Finnish documentation), Animal Welfare Legislation, (and further ammendments about the same, EU Regulations with regards to Animal Health, EU Regulations regarding transport, the food act, becoming a vet and dealing with waste. Environmental Health assessments are discussed here and information about an EU-funded project looking at these issues is discussed here.

Unfortunately, part of the reason why I cannot claim that this list covers everything of relevance is purely and simply because the legislation is generally not available in English. This makes it almost impossible to find when farm owners like myself try to track it down. This is actually a real issue due to the number of sledfarms in Scandinavia which are either owned or run by foreigners. (This is not-surprising, given that it is impossible to follow this passion elsewhere in Europe).

I do know, for instance, that a group of interested vets in Rovaniemi (part of Lapland's regional state administrative agencies (Lapin aleuhallintovirasto), started to put together some 'points' to work against relating to sleddog welfare - but I couldn't find any information about their meetings on the relevant websites e.g. here.

Similarly the EU project which was set up to look at quality and safety in sleddog industry presented a couple of 'official' booklets on the subject which were written by the project leader (who had more expertise in reindeer husbandry than in dogsledding and who, unfortunately, did not involve any sleddog companies in the process. I cannot access the material since it is in Finnish but my husband said that they weren't worth translating, since they were pretty much the same ones that she had written at the end of an EU reindeer-husbandry project but with the name switched to sleddogs. Clearly that was a good opportunity for the development of something useful for the industry which somehow just got missed.

Since this is clearly one of the key business areas in which foreign investors / entrepreneurs can be attracted to these regions, the need for language accessibility is particularly important and this should also be recognised by authorities when drawing up new laws and recommendations.

What should be done, moving forward?

What IS clear is that, given how important this industry is within the tourism market in Finland, there is a real need for work to be done in this area. Ideally before the accepted standards become more understood by the participating clients who might not just speak with their feet, by going to the better farms, but who could demand a more substantive change (eg with greyhound racing in Australia at present) which could negatively impact the industry as a whole.

We have started to draw up our own ideas for both 'codes of best practice' and minimal standard regulations that might work for Finland / Scandinavia using both current legislation and the codes and regulations BC developed as a starting point and these have been shared with the area vets who, in turn, are offering them up to those looking at these laws at present. These are definitely a work in progress but it is a job that is clearly overdue.