Compulsory Measures and the Welfare Checklist

#Four diseases, four different answers

Ask a room of South African farmers who may legally put the needle in and you get two confident, opposite answers: only a vet may vaccinate, or it is your animal so it is your call. Both are wrong. The regulations settle it disease by disease:

Anthrax — by the responsible person. That is you.
Brucellosis — by the responsible person, inside a hard age window and once in the animal's life.
Rabies — by an officer, veterinarian or authorised person. Not you.
Foot-and-mouth disease — only government officials.

You cannot learn one rule and apply it across the board. You read the Table 2 column for the disease in front of you — and those measures bind you on a farm that has never had a case.

#The measures that bind you whether you know them or not

Animal Diseases Act 35 of 1984 s11(1) puts three duties on you: take all reasonable steps to prevent infection, spread and parasites; apply prescribed or suitable treatment on suspicion; and immediately report any controlled disease to the director. s11(2) extends that reporting duty to any person who finds a suspected case.

The addressees differ. Controlled diseases go to the director; notifiable diseases — bluetongue, bovine malignant catarrhal fever, lumpy skin disease, Rift Valley fever, strangles and swine erysipelas — go to the responsible state veterinarian under reg 12A. The state vet is the right first call for both.

The legal position

Table 2, Animal Diseases Regulations R2026 of 1986 — the measures with the widest reach. These are statutory obligations expressed as age and interval windows, not a clinical protocol. This course gives no product, no dose and no route; those come from the registered label and your veterinarian.

Anthrax — all cattle in the Republic immunised once every 12 months with an efficient remedy, by the responsible person.
Brucellosis — all heifers between 4 and 8 months immunised once. No bovine over 8 months may be vaccinated without the responsible State Veterinarian's written consent. Sheep and she-goat lambs may be done at weaning.
African horse sickness — under GN 2318 of 29 July 2022, all equines in the Republic except those in the AHS free and surveillance zones must be immunised by the responsible person twice before the age of 18 months and then once every year thereafter. Equines inside the free, surveillance and protection zones are immunised only as the director determines.
Sheep scab — all sheep moved onto a person's land treated twice before mingling with the resident flock; infected and contact animals dipped or treated at least twice at intervals of not less than 7 and not more than 10 days. Which registered remedy, and how it is applied, comes from the label and your veterinarian.
Rabies — all dogs and cats in the Republic immunised at three months, with a second vaccination within 12 months — and, unusually, the regulation requires this to be done by an officer, veterinarian or authorised person, not by the responsible person.

Two of those need a second look. The AHS window traps anyone keeping horses or donkeys. The vaccination period widely quoted for the controlled area is a determination by the director, not text in the regulation — imposed because vaccine virus carried by midges has itself caused outbreaks. It binds you, and it can change without the regulation changing, so get the current dates from the state veterinarian each year rather than learning them once.

Sheep scab runs backwards from how farmers expect. The reporting trigger is the clinical picture, not a diagnosis — any skin condition in sheep with itching, tangled wool, or bare scabby patches. You do not diagnose it: you quarantine, you do not move the animals, and you call the state vet.

#Brucellosis: the vaccine that leaves a record

Brucellosis carries the sharpest legal edges, because the vaccine itself marks the animal for life. Only two Brucella vaccines are approved for cattle in South Africa, and statutory use of S19 is limited to the single inoculation of heifers between four and eight months. Using it more than once in the same animal is illegal, because of the persistent vaccine reactions it causes. No animal outside that window may be given S19 except with the written permission of the Provincial Director, and no bull of any age may be inoculated with either approved vaccine — orchitis and infertility.

Do this on the farm

The brucellosis compliance sequence, in order.

Diarise heifer calves so the 4-to-8-month window is a routine handling job. Miss it and the route back is written permission from the Provincial Director — an application, not a phone call.
Never put S19 into a bull, at any age, for any reason.
Never repeat S19 in an animal that has had it. The record follows the cow for life.
On a dairy herd, use the bulk milk ring test as the departmental manual describes it — cheap, efficient monitoring of herd status, explicitly not a sole diagnostic criterion. A positive tank starts an investigation; it does not end one.
Confirmed reactors are C-branded on the right side of the neck, the counterpart to the T on the left for tuberculosis. Your own ownership brand may not go on the neck at all — that is a separate rule, in the marking regulations.
Treat brucellosis as a zoonosis in your own household. Self-inoculation with the live vaccine infects the vaccinator.

Branding a controlled-disease reactor is an explicit animal health technician competency under the SAVC's Day 1 Skills — and on most South African farms the AHT is the professional you actually see.

#The feed ban is narrower than the slogan

Every farmer has heard "you may not feed ruminant protein to ruminants". The regulation is more specific: "No person shall feed any protein of ruminant origin (except milk and milk products) to any animals other than predators and carnivores, except with the written approval of the director."

Milk and milk products are outside the ban. Predators and carnivores are outside it — the farm dogs and cats are not caught. And the director may approve exceptions in writing, which is how ruminant blood meal reaches non-ruminant rations. If your fodder plan leans on a by-product, establish which side of that sentence it falls on before you order a tonne.

#The cruelty statute, read as a farm audit

The Animals Protection Act 71 of 1962 is not written as a checklist, but it functions as one. Its definition of "animal" covers every equine, bovine, sheep, goat, pig, fowl, ostrich, dog and cat, any other domestic animal or bird, and any wild animal, bird or reptile in captivity or under human control — so it reaches the guardian dog, the working donkey and the captive game as readily as the cattle.

Do this on the farm

Walk your farm against s2(1). Each line is a listed offence, not a guideline.

(b) Confinement and tethering — inadequate space, ventilation, light, or shelter from heat, cold or weather. Look at the kraal, the calf pen and the poultry pen in a Highveld June.
(c) Feed and water — unnecessarily starving or under-feeding, or denying water or food. On sourveld that is the winter protein collapse: the fodder-flow plan is a welfare document.
(e) Condition and care — an owner deliberately or negligently keeping an animal in a dirty or parasitic condition; failing to procure veterinary treatment they are able to procure; or failing to destroy an animal so injured or diseased that prolonging its life would be cruel.
(i) Working an unfit animal — harness sores, lameness, poor condition on the working donkey or draught ox.
(m) Transport — conditions, duration, distance, shelter, food, water and rest.
(p) Abandonment, and (q) an owner permitting any of these. (r) Negligently causing unnecessary suffering.

Then read s2(2): an owner is deemed to have permitted an act if reasonable care and supervision could have prevented it. Delegating to a herder is not a defence.

Read (e) twice. It is the line a low-input philosophy walks into: a suffering animal left because "it might come right", or an effective registered treatment withheld on principle. Withholding it is a listed offence, not regenerative practice.

#When the SPCA arrives

An SPCA officer authorised in writing under the hand of the magistrate of the district may seize an animal that needs immediate care, or where seizure is reasonably necessary to prevent cruelty — and must then report the seizure to the nearest police station within 24 hours. The court may also award damages under s4.

The penalty on the face of s2(1) is a fine not exceeding R4 000 or, in default, imprisonment not exceeding twelve months. The section still prints "a whipping not exceeding six strokes" for wilful and aggravated conduct. That is not live law — corporal punishment as a criminal sentence was abolished by the Abolition of Corporal Punishment Act 33 of 1997, commenced 5 September 1997. (The effective maximum fine, once the Adjustment of Fines Act 101 of 1991 ratio is applied, could not be confirmed here — R4 000 is almost certainly not the practical ceiling.)

R4 000 is the wrong number to think about anyway. The real cost of a conviction is the seizure of your animals, the loss of a retail listing, and your reputation in a district where everyone buys from everyone.

Contested — here is both sides

Is R5 million for a wattle tree and R4 000 for a starved cow a defensible set of priorities?

The criticism. The Alien and Invasive Species Regulations carry up to R5 million or five years, rising to R10 million or ten years on repeat; the Animals Protection Act carries R4 000 or twelve months. On the face of it South African law values a riverbank more than a suffering animal, and the gap is largely an accident of when each statute was drafted.

The counter. Biodiversity harm is irreversible and diffuse: nobody has standing, nobody sees it happen, and by the time it is visible the catchment is gone, so the deterrent must do all the work. Cruelty has an identifiable victim, an immediate witness and a fuller remedy set — seizure, forfeiture, damages under s4, and the market consequences above.

Neither reading changes what you do on Monday. But it tells you something true about enforcement here: the fine is rarely the thing that hurts.

#What this changes

Print the Table 2 entries for the species you actually keep — not all of them — and put the dates in the same diary as your handling days. Anthrax every twelve months, timed with the late-winter handling; heifers inside their 4-to-8-month window; sheep treated twice before they touch the resident flock; equines against the current AHS determination; and the farm dogs done by a vet or authorised person, not by you.

Then walk the farm against s2(1) with someone who will disagree with you, because the shelter you stopped seeing five years ago is the one an inspector photographs first.

#Check yourself

4 questions — answers explained as you go

1A heifer calf missed her brucellosis window and is now ten months old. What does the law allow?
Why: Table 2 makes the single inoculation of heifers at 4–8 months compulsory, and no animal outside that window may be given S19 except with written permission. Repeating S19 is illegal because of the persistent vaccine reactions it causes — so the route back is an application, not a second needle.
2Who may lawfully carry out the compulsory rabies vaccination of your farm dogs?
Why: Rabies breaks the pattern. Anthrax, brucellosis and African horse sickness are worded "by the responsible person", so the owner may do them; rabies is worded "by an officer, veterinarian or authorised person", and FMD is stricter still — only government officials. Read the column for the disease in front of you rather than generalising from the last one.
3Your herder leaves twenty ewes without water over a hot weekend while you are away. Where does the Animals Protection Act put the liability?
Why: s2(2) makes delegation useless as a defence. The question a court asks is whether reasonable care and supervision could have prevented it — training, systems and checking. That is why the welfare audit is a management job, not a moral one.
4Which of these is a listed offence under Animals Protection Act s2(1)?
Why: s2(1)(e) makes both failing to procure treatment you can procure and failing to destroy a hopeless case offences — leaving a suffering animal to "see if it comes right" is the version farmers walk into. Home slaughter for the household is permitted under the Meat Safety Act, and anthrax vaccination by the responsible person is exactly what Table 2 requires.