#Animal Welfare
Aust. National Kennel Council, Aust. Veterinary Assoc., Members of the Aust. Canine Eye Scheme

If you go to the above website you will be able to print this out to read, at your leisure, before signing the petition at the bottom of this page.

This is a petition for registered breeders only. All other interested parties please use the forum page to have your say. Everybody welcome. All comments welcome. Be anonymous on the forum page, if you wish.

We have two issues with ACES, which are:
A) the implementation of THIS particular eye scheme (ACES) and in fact
B) the implementation of ANY eye scheme or regulation for breeders.

If you, as a breeder, have any reservations about either of these issues, please sign this petition. To make it a credible appeal, please include your breed and registration number. It is much easier to stop ACES at this point until all the problems have been resolved rather than in a number of years when we are dealing with the consequences and the fallout of the ACES and other schemes.

The Australian Canine Eye Scheme (ACES) has been presented to breeders as a tool to deal with eye health problems in recognised dog breeds. While the sentiments of ACES are those that are held by all respectable breeders in Australia, its draconian regulation of breeders is unnecessary and particularly unacceptable under the conditions set out by ACES. All responsible breeders have been testing their breeding stock appropriately and with great success without the hindrance of any scheme for many years. In its current form, outlined in the documents: Information For Owners and Rules and Procedures, there are many anomalies and distressful concerns which affect to control all breeders, even those who are lucky enough to have breeds that do not have any known genetic eye diseases at this time. ACES is a precedence for other intrusive schemes in the future. All breeders should reject ACES for the reasons discussed below. We would ask all breeders to carefully read the above named documents.

These two documents are important and can also be found at: http://www.ava.com.au . Click on the Veterinary Information button on the left hand side of the page, open the Australian Canine Eye Scheme page and go to the very bottom of the page to where it says: Down load Information For Owners and Down load AVA-ANKC-ACES Rules.


This critical passage, glossed over in the Rules and Procedures document, is the key:

“Following the launch of the Australian Canine Eye Scheme, all ANKC-affiliated National Breed Councils and unrepresented breed clubs in each State were contacted by the ACES Chief Panellist to explain the aims of ACES, before inviting a nomination on behalf of their breed to either the Open or Closed Register with respect to the reporting of canine inherited disease. These Registers are the responsibility of ANKC. For any breed on the Open Register, all results from any known inherited condition in that breed (eye conditions, hip and elbow scores, tests for congenital heart disease etc.) will be released for publication. By submitting dogs for certification, the owner agrees to this and relinquishes all rights to keep the results confidential.”

ACES is setting a precedence. It will not be long before many more schemes are added - as mentioned above: " (eye conditions, hip and elbow scores, tests for congenital heart disease etc.)"
Note also that breeders were not asked if they wanted ACES, it has been forced on them from out of the blue. The only input we have been offered in ACES has been to decide if we want our breeds registered on an Open or a Closed Register. Note also in this document (Rules and Procedures) it says:
“… National Breed Councils and unrepresented breed clubs in each State were contacted by the ACES Chief Panellist to explain the aims of ACES…”.
This is one of many inaccurate and misleading statements we see in their documents. It is known that at least one club was never contacted by the Chief Panellist, so that would make one think there could be others.

Note also an example of the draconian language we referred to previously:
”… relinquishes all rights…”.


• ACES does not present anything of value that does not already exist -

ACES has been offered to breeders as if it has benefits that have not been available to breeders before: -
“The aim of the scheme is to provide a means by which purebred dogs in any registered breed may be assessed for defects that affect the normal function of the eye or that may threaten vision.”
This is not accurate because the means are already there and in use. Ophthalmologists have been doing exactly the same tests for breeders for years – all without ACES. For many years all responsible breeders have been testing their puppies and breeding stock with registered ophthalmologists (and do indeed test for as many genetic diseases as possible - not just eyes). In fact ACES gives less to breeder. We get less service for higher costs.

Examples of less service:
Under ACES the results of all tests will be certified as Affected or Unaffected -see Information for Owner document:
“… certificate is issued with results of “affected” or “unaffected”.
In some breeds, particularly where the disease has a range of expression, this does not give the information required to make responsible puppy homings or to make responsible breeding choices. Prior to ACES ophthalmologists were happy to give further information, but have been clearly instructed in these procedures not to do so -
“Examining panellists will be discouraged from entering into any discussion on matters concerning particular eye conditions or their inheritance in any given breed.”
(The examining panellist is your ophthalmologist.) We also use to get an individual certificate for each animal including puppies now all puppies will be listed on one sheet.
“The ACES Litter Screening Certificate (Appendix 5) is used to collect information on all pups in litters aged less than twelve weeks.”

Example of the rise in costs:
September 2006, prior to the implementation of ACES, the cost of one particular examination was $55.00 per puppy. As of February 2007, exactly the same examination being done under ACES was quoted by the same ophthalmology clinic as $88 per puppy and if that same examination is taken, but not under ACES, then the cost rises to $154.00 per puppy.

It is patently: less service – higher costs!

• Even though ACES is promoted as voluntary, here are at least four coercive elements that push breeders into using ACES -

a) The sneakiness of making breeders pay exorbitant extra costs for the same service just because they don’t wish to test under ACES is nothing short of duress.
b) Here is another example of those seemingly underhand tactics. If the same examination is undertaken with a registered ophthalmologist, (who would have the same qualifications), but is who is not a panellist examiner, i.e. not a member of ACES, you will not be able to claim that your dogs’ eye checks are as good as or equivalent to that done through ACES. This is quoted from the Rules and Procedures document:
“No eye test result issued by a veterinarian who is not a current appointee to the ACES Examining Panel may be represented as being an ‘ACES eye exam’ or in any way equivalent to an AVA-ANKC Australian Canine Eye Scheme certificate.”
c) And then the ANKC gets into the act and backs the ACES to this extent:
“The ANKC endorses ACES as the only eye certification system authorised to lodge individual results with the ANKC’s inherited diseases database.”
d) Going on to say;
“…and for certain higher risk breeds, ANKC has the power to insist on an ‘unaffected’ test report as a prerequisite to litter registration”.
If the ANKC can insist on this for “certain higher risk breeds” then it can do the same for all breeds.

It should now be evident that even though is it stated a number of times in these documents that this scheme is voluntary –this NOT the real position desired by ACES or the ANKC.

• ACES accepts no accountability:

Please make sure you understand this next section really well.

From the Rules and Procedures document:
(1) Examinations are conducted by specialist registered veterinarians who have been appointed by AVA Board to the ACES examining panel, on the understanding that each member has made adequate provision against his or her professional liability. In no event shall AVA be liable for any incidental or consequential damages arising from any negligent acts or omissions arising out of the examination.

(2) AVA does not make any warranties or representations regarding the quality, accuracy, completeness or authenticity of the information provided on the ACES Eye Examination Certificate.
• accept liability for any loss arising out of the use of said information and / or the reliance placed on it, by the owner or any other party

Subject to the normal veterinary certification standards required under the various State Acts, ACES Panellists do not accept individual or collective liability for any consequential loss arising out of the use of information provided on an ACES Certificate, or the reliance placed upon it by the owner or any other party.”

The AVA and ACES are attempting to avoid any accountability or liability here, which under common law of course they cannot do. However, this statement, that ACES Panellists (one of whom will be your ophthalmologist)
“... do not accept individual or collective liability for any consequential loss arising out of the use of information provided on an ACES Certificate, or the reliance placed upon it by the owner or any other party.”
means that the AVA is indicating the ACES Certificate is not worth the paper it is written on. Why would anyone want to pay their high fees for such a document?

One must also question the actions and the competence of the ANKC when they commit themselves so wholly to ACES and to such a valueless certification.
“…The Australian National Council recognises ACES as the only eye certification system authorised to lodge individual data with the ANKC’s inherited diseases data base...”

Now for another area where the accountability of ACES and the examining panellist becomes highly questionable and raises acute alarm - again from the Rules and Procedures document:

“The following documents must be sighted by the examining panellist at the time of the examination:

(iv) The original registration certificate issued by a State Canine Control or the registering authority in the country of origin, endorsed with a record of permanent identification (microchip or tattoo).
(Why do they need the dogs original registration certificate, if the dog is microchiped or tatooed?)

(i) Any change of ownership documentation or original export certificate from the country of origin.
(Again, if the dog can be identified by a microchip or tattoo, why would this documentation be required?)

(ii) Any previous eye certificates issued by a veterinary eye specialist in Australia or overseas.
(Again why?)

(iv) A formal transcript of any genetic test results issued by a recognised commercial testing laboratory, that the owner wishes to see included in ANKC’s multi-breed inherited diseases database.
(ANY genetic test results? Why? )


If any of these documents are held but not presented, then the examination may proceed but the results will not be made available (even verbally) and the certificate will not be issued until the missing documents have been sighted by the ACES Panellist.”

What an outrageous set of demands! Of course, now that we have the means, a dog should be able to be indisputably identified before examinations take place. However the demand that any previous results be presented before any results are made available, even verbally, can only be seen as skewing any examination results. All examinations should be totally independent, otherwise the results are worthless.

Also if you are seeking a second opinion or are in dispute with your ophthalmologist the above means that you have to show all previous documentation before you can obtain any further results. This is also alarming! How independent, and uninfluenced would you expect any second opinion to be? This second opinion could only be seen as being highly prejudiced.

The best conclusion that can be drawn from the Provision and Liability section and the scandalous order for all previous eye documentation prior to any further testing, is that the AVA does not believe in the abilities of its ACES examining panellists.

It is also it hard to fathom why any ophthalmologist would wish to belong to ACES when it appears to place no faith in their competence and practices.

And why would any breeder have any faith in this kind of scheme?

Each ACES examiner should be able to stand confidently behind their individual findings.

• Another area of concern are the anomalies in Schedules 1 and 2

Already it is evident there are anomalies in certain breeds listed in these Schedules. If there is interbreeding between varieties, e.g. Collies, then obviously you would expect both varieties to be subject to the same eye diseases, but this is not the case. Also in both schedule lists, which appear to have been pulled directly from the British Veterinarian Association’s website, there are diseases listed in certain breeds, which are not seen in those same breeds in Australia. And then to make it even more confusing, there is at least one breed on this list where one of the more prominent eye diseases in this breed is not even listed. The Australian Shepherd is susceptible to CEA but is not listed in either schedule

Scary stuff! We don’t want or need ACES, particularly with the unprofessional nature by which it seems, through these anomalies, to have been established.

• Open/Closed Registers:

On talking to many breeders it seems that most believe erroneously that the only difference between an Open and a Closed Register is that: on a Closed Register results will not be make public, and on an Open Register they will be public. This is the most benign part of these Registers.

In the Information for Owners document it clearly states:
“You will need to get the latest information on conditions relevant to your breed from an ACES Panellist or ANKC, especially if you are uncertain whether the National Breed Council for your breed has elected inclusion on the ANKC-endorsed Open or Closed Register. “

“For Open Register breeds, both the sire and dam will usually be expected to have current eye certificates showing them to be unaffected.”

“By seeking to be placed on an ANKC-endorsed Open Register for inherited disease surveillance, the National Breed Council for that breed is making a clear statement on behalf of all active breeders and club members. They are saying that optimum health standards are important to them, and that while all disease testing is undertaken voluntarily, adherence to a strict policy of disease surveillance is a prerequisite for any serious breeding program. They realise that by offering all puppy buyers such a transparent commitment to quality assurance, they are expressing a higher degree of confidence in the general health”

Optimum means that it can’t be better - so they have to be meaning unaffected animals. Also note the last sentence:
“... offering all puppy buyers such a transparent commitment to quality assurance, they are expressing a higher degree of confidence in the general health.”
How can just an eye examination promote a higher degree of confidence in the general health of the dog? General means broad or overall. Are they suggesting an eye certificate will promote confidence in the overall health of the dog? We think they are talking about when they add many more schemes as we anticipated.

Also don’t be fooled by the suggestion that, ACES or any scheme, offers a higher degree of confidence to the puppy buyers, it is the testing, by any qualified ophthalmologist, that does that, and responsible breeders are and have been testing for years with their ophthalmologists.

“Closed Register breeds may not require that both mating partners be certified unaffected, .”
Please note the language here – it does not say “will not” – only “may not” and…. “both” mating partners. Please don’t forget it has already been stated,
"Individual National Breed Councils will set their own policy on whether mating partners need to be ACES ‘unaffected’ or just ACES ‘tested’, and for certain higher risk breeds, ANKC has the power to insist on an ‘unaffected’ test report as a prerequisite to litter registration.”

The greatest flaw with these proposed Registers is that they are trying to deal with complicated genetics in a simplistic and naïve way. We know that all living things carry deleterious genes. There is no such thing as a genetically flawless individual – even in humans. Also these genetic flaws can range from very minor, causing no loss of function, no pain and do not decrease life expectancy to the other extreme where they cause death before or at birth. In between these two extremes we have varying degrees of debility, pain and life expectancy. This means we should prioritise the diseases according to these criteria. Then we need to discover the genetic inheritance i.e. dominant, recessive, sex linked, etc., and whether the disease is autosomal or polysomal. When this is done we need to factor in the breeds' breeding population and determine the extent of the disease in the population. Only then, in the case of dogs, can we know how to breed and what to breed. Some of the genetics for disease we do know, others we are still trying to determine. Eliminating a dog from a breeding pool on one genetic fault and not knowing the exact genomics of the fault achieves nothing and in fact can be detrimental to the breed. These registers are trying remove dogs from the gene pool on one fault, often without knowing the mode of inheritance and how many genes are involved as in the case of CEA where research is still continuing.

The above are only examples of the problems, anomalies and questions raised in both The Information For Owners and the Rule and Procedures Documents. There are other important problems, such as the following, which are not discussed here but which should be noted when you read the document:
• frequency of testing
• procedures for disputes or second opinions
• availability of examining panellists
• limitation of regional and rural services, etc.
• litter registrations and privacy issues
• independent accreditation & monitoring of ACES



• Strangulation by Regulation:

One criticism is that if we do not have compulsory testing then some breeders will not test. The truth is – even if we do have compulsory testing these same breeders will not test, but more importantly we will also see responsible breeders who have always tested leave the sport because of over regulation. If you think this is good, think again. Less breeders, less diversity within the breeds, less fees to support our hobby, i.e. funds for the ANKC and to Clubs, which means higher fees and less services for those remaining. We have already seen registrations drop alarmingly i.e. Collie registrations in 1986 were 2,571, in 1996 – 1,186, and in 2006 - 493 This is a trend across the breeds. Why? – regulation is one of the key elements. Regulation by federal law, regulation by state law, regulation by local councils, regulations by affiliated bodies.

History shows us that regulation of anything always makes for an underground component too. This Eye Scheme, ACES, will make some breeders who have always tested and register all puppies, now only test the puppies they are interested in and only register puppies they are interested in. Other breeders may decide not to test at all and that is a sad state of affairs. ACES adds nothing, it encourages the opposite to its stated desires.

• Peer and Consumer Pressure

For those worried about the ethics of the next breeder, peer pressure and/or consumer pressure are stronger tools than any scheme for ensuring breeders become learned and responsible. Because of how easily information is disseminated today, especially with the internet, both breeders and prospective owners are very aware of what good breeding practices entail and all their rights. All responsible breeders are dedicated to the health and robustness of their breed and keep themselves informed of current research and tests. Responsible breeders see this as being as the very basis of being a breeder. They don’t need rules and regulations to be responsible – just good education opportunities.

• Breeders (that’s us) Lead the Research

It is also a known fact that it is often the breeders who lead the research into health problems. For example in collies, for many years breeders were experiencing results that make it clear that CEA would more likely be polyfactorial, although the scientific belief, until very recently, was that it was, autosomal recessive.

• Breeders Should Have Full Rights and Full Responsibilities

If we want to be breeders, we should have all the rights, responsibilities, and choices that this position holds. We do not need to be dumbed down by regulation that takes away our choices. Rather the efforts to clean our breeds of many of the diseases will be through research and education not through regulation and restrictions.

• Genetic Diversity

Genetic diversity is a catchcry we hear often. Eliminating dogs from the gene pool for one genetic disorder can potential cause us problems of the highest magnitude. Please read what happened in the cited reference, (Bad Genes, Babies and Bath Water by C. A. Sharp) when breeders decided to eliminate one genetic health problem by removing all affected dogs from the breeding pool. We are breeding for the whole dog. We will never be free of genetic disease, due to the fact that dogs are evolving like any other species on earth. There will continue to be spontaneous mutations, both somatic and germ cell – the very thing that allows a species to evolve. That is the nature of life. Some of these genetic changes will be very deleterious and cause disease, occasionally some will be beneficial, but we can not delete them all. However with education we can all breed wisely and control many of these diseases. Regulations and schemes will not make us wise.

• Proteomics

It is common that a gene displaying a particular phenotype is thought of as a gene for that phenotype when this is not the case. A gene, all genes, simply encode for a protein. That is all they do. Depending on what the protein’s role is in the metabolism of the cell, and it is almost always multiple roles, will determine the phenotypic consequences. For example, a protein prominent in connective tissue can have varying consequences in different organs of the body. No one knows yet the proteins responsible for example in CEA and therefore what other functions those same proteins may be performing in other tissues. The interesting thing is that a protein causing a defect in one area, may be causing a beneficial affect in different area. Eliminating an allele or alleles because of perfunctory opinion about their deleteriousness can lead to unanticipated consequences.

• One Last Question:

A question to ask ourselves is: have we seen great health improvement in dogs in countries where a lot of health testing and regulation of breeding practices are carried out? Are they living longer, healthier lives? Through correspondence with several breeders from countries where hip/eye and temperament testing is mandatory they still face the same concerns that we face with probably just as many health issues and their dogs do not live longer lives. These breeders feel very restricted and often believe they have not been able to make the wisest of choices in their breeding programs due to all the restrictions they have to deal with.


What we need is education and research, not limitations and regulations.
ACES offers no education, limits information and reduces the breeder facility for research while forcing regulation and restrictions upon us. A better solution would be a scheme offering access to education and increased genetic and breeding research from an ANKA or AVA body rather than a membership based entity seemingly established purely for feeding themselves fees.

If you as still unsure please take the time to read these articles:

Bad Genes, Babies and Bathwater http://www.ashgi.org/articles/breeding_bad_genes.htm
Genetic Load http://www.netpets.org/cats/reference/genetics/load.html
The Misuse of Health Testing http://www.kismetsighthounds.com/testing.htm
Breeding In Germany http://www.sheltie.com/germany.htm

We, the undersigned registered Australian dog breeders, request that the Australian Canine Eye Scheme be abolished.

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The Abolish Australian Canine Eye Scheme (ACES) petition to Aust. National Kennel Council, Aust. Veterinary Assoc., Members of the Aust. Canine Eye Scheme was written by Australian Dog Breeder and is in the category Animal Welfare at GoPetition.