A better model for measuring welfare in wild animal sanctuaries

A better model for measuring welfare in wild animal sanctuaries

 Animal care in tourism in South Africa is in a mess, and the industry’s trying to do what it can to counteract the effects of the mavericks and the pseudo-experts, and even the animal rights agendas that often compromise the very wildlife they’re designed to protect. But is the tourism industry’s current, country-wide campaign to create an ‘ethical framework for animal interactions’ going to untie the Gordian knot? In this article, we argue that the results would be impossible to enforce – and we offer a solution that would have the legal muscle to ensure compliance and, most importantly, that would put the animals’ needs, rather than the tourism industry’s, first.

And in the process… greatly improve the industry’s ability to deliver on South Africa’s brand promise.

A better model for measuring welfare in wild animal sanctuaries


We’ve all seen the horrifying headlines – the animals that’re cowed into submission to render them tame enough to interact with tourists, the cuddly cubs that’re destined for the canned hunting industry – and we’ve all decided to do something about it.

In November, 2018, the Southern Africa Tourism Services Association announced[1] that, ‘”The development of a definition, ethical framework and self-regulation ‘by the tourism industry, for the tourism industry’ around the contentious issue of Animal Interaction has finally been given the green light…

But is it really going to achieve anything? Is it the right way to go?

We think not. It’s like asking the authorities who treat addiction to write road laws to prevent deaths from drunk driving.

No matter how much ‘stakeholder engagement’ takes place (why can’t we just be honest and call it ‘discussion’?) – the most obvious weakness inherent in any ‘best practice guidelines’ written by organisations like SATSA or their consultants – or, indeed, by supply-side organisations like the Association of British Travel Agents (ABTA) or the Dutch Association of Travel Agents (ANVR) – is that they cannot be regulated.

At best, they’re wish lists. At worst – greenwashing.

Too, the danger in the current process comes from the fact that guidelines for best practice written by the tourism industry will always uphold the tourism agenda: they’re going to be written to make people happy, regardless of whether they fail the animals.

From the tourism point of view, the practical manifestation of this is that visitors who believe they’re choosing ethically have no idea of the consequences of what they’re doing.

For the animals, it’s a lot worse.

Remember those lion cubs?


The legal framework that should govern the debate is complicated. Generally, animal care falls within the purview of the Department of Agriculture, Forestry and Fisheries (DAFF), while wildlife management, TOPS regulations (Threatened or Protected Species regulations) and NEMBA – the National Environmental Management: Biodiversity Act – fall under the Department of Environmental Affairs (DEA).

Both of these organisations are empowered to create and publish legally binding regulations, norms and standards.

Given this framework, the correct – best practice, most effective – route would be to to develop a professional body that would in turn develop legally enforceable accreditation criteria that would govern the treatment of animals in care.

This would overcome the challenges around the questions of who regulates, how they regulate, and who has the skills to regulate.

According to SAQA[2], “The recognition of professional bodies [as they’re defined in the National Qualifications Framework Act] will contribute to strengthening social responsiveness and accountability within professions and promoting pride in association for all professions.”

Such a body must seek to develop competency by defining modules of study and assessment processes for the different levels of accreditation – and assess and upgrade these standards every two years.

The professional body must also become the vehicle for engagement with all stakeholders – which is important for inclusivity, and, amongst other things, because government departments are required by law to recognise such bodies when they’re created and maintained in terms of the Act. (They have no such obligation when it comes to the tourism industry’s self-defined codes of practice.)

Given the widely different requirements of the various species under care (elephants, big cats, birds, reptiles), and the various forms of  care (game reserves, wildlife sanctuaries, rehabilitation facilities, exhibition centres, etc.), this professional body would need to establish sections or departments representing the different areas of specialty. This means that each area of specialty would develop its own, enforceable norms and standards, and its own training modules.


The problem that underlies the question of what’s best for wildlife in captivity is that we often don’t know what we don’t know – and we need to have the humility to understand that we don’t know it. We need to guard against arrogance regarding our knowledge because, as Quassim Cassam, Professor of Philosophy at the University of Warwick points out in his book, Vices of The Mind[3], intellectual arrogance is an epistemic vice that obstructs knowledge. This can have far-reaching, even deadly implications: Prof. Cassam makes the case that the reason for the ongoing crisis in Iraq is the fact that senior members of President George Bush’s administration refused to acknowledge the gaps in their knowledge before they ordered the invasion. They couldn’t contain the problem that would arise, because they refused to see the problem – and as a result, more than 460,000 people have died.

However, using the processes inherent in ethical reasoning – which are designed to ensure objectivity, and to deliver scientifically sound outcomes not influenced by individuals or groups with specific agendas – it is possible to establish the correct norms and standards for animal welfare and care.

This kind of work has already begun in South Africa: collaboration agreements have been signed between the National Research Foundation[4] and the Department Bio-ethics at Italy’s University of Padova, and between Padova and the faculty of Life Sciences at the University of Kwazulu-Natal. Additionally, DAFF commissioned a scientific assessment of elephant welfare in 2013, which was to have served as a first step to the study of other wild and domesticated animals. (Full disclosure: through Conservation Guardians, which he founded, Greg Vogt, a co-author of this article, has worked with Padova’s head of department, Professor Barbara de Mori[5], since 2013.)

The process involves:

  • Defining the purpose for keeping animals in captivity;
  • Designing a simple model for assessing places that keep wild animals in captivity;
  • Defining each place’s conservation integrity;
  • Scientifically assessing the level of animal care in each place;
  • Sharing the outcomes with owners and managers, with suggestions for improvements where necessary; and
  • Training the people who work directly with with animals.


Besides settling the practical and ethical questions around assessing animal care facilities, the norms and standards developed by a professional body would serve to help the DEA to clearly define the country’s conservation purpose – which would feed into its brand promise.

Since enormous numbers of people visit interactive wildlife places, a key purpose should be to share the country’s conservation strategies and positions: our position on the ivory and rhino horn trades, on sustainability, on biodiversity, and so on – all of which should be defined by the DEA, and taught in modules for guides working in these facilities.

And those facilities should be measured on the standard of their conservation messages, too, of course.


The  establishment of a professional body for the animal welfare sector of the tourism industry would fulfill SATSA’s laudable quest to do the right thing by the creatures in our care. It would also provide an avenue for engaging with government, and establish scientific methods for assessing welfare standards – and thereby for accrediting welfare facilities based on each facility’s conservation score.

This would also help  SA Tourism – which has always grappled with how to connect with conservation – in its work of communicating the country’s conservation messages. And, of course, any reduction of the disconnect between conservation and our marketing campaigns will always have a positive outcome.

In short: scientific assessment of animal facilities undertaken by a registered professional body would deliver a measureable, governable, enforceable level of objectivity that “self-regulation ‘by the tourism industry, for the tourism industry’” can never achieve.


[1] “Now the real work starts” – SATSA animal interaction initiative kicks off: www.satsa.com/now-the-real-work-starts-satsa-animal-interaction-initiative-kicks-off

[2] Policy and Criteria for Recognising a Professional Body and Registering a Professional Designation for the Purposes of the National Qualifications Framework Act, Act 67 of 2008 (as amended, March 2018) www.saqa.org.za/docs/pol/2018/28Mar18_AMENDED%20professional%20bodies%20policy.pdf

[3] https://iai.tv/articles/vices-of-the-mind-auid-1220

[4] https://nationalgovernment.co.za/units/view/258/national-research-foundation-nrf

[5] Prof Barbara de Mori, Department of Comparative Biomedicine and Food Science, University of Padova. PHD in Ethics . Adjunct Professor in the scientific field of Bioethics. Teaches Veterinary Ethics, Wildlife and Conservation Ethics, and Animal Welfare Ethics. https://en.didattica.unipd.it/off/docente/5F2678379CED400546FC5A815E007A0D

unsplash-logoPawan Sharma