The Elephant in The Room: The State of Welfare for UK Zoo Elephants

Should elephants be kept in captivity? This controversial question has caused a rift in the scientific community and public eye alike. We know that elephants are faring notoriously poorly in zoos worldwide; in the early 2000’s, zoo elephant welfare was widely criticised in numerous reports (for example this one), and in 2008 the situation was dire enough that the UK government commissioned a scientific inquiry into the state of elephant welfare in UK zoos, which they then reviewed in 2010 alongside other studies. This report raised a LOT of concerns, and ultimately prompted discussion about whether UK zoos should cease to house elephants altogether if welfare wasn’t drastically improved. In all of this controversy however, we can’t forget about wild populations – which have been steadily declining for years due to human interference. Currently, African elephants are listed as Vulnerable and Asian elephants Endangered. So, it’s unlikely captive breeding will stop anytime soon, as maintaining sustainable captive populations is considered by many to be an important fail-safe for future species survival. (Though others say saving a species should not be done at the expense of the individual – this really comes down to your own personal moral compass). It’s also important to remember that many elephants are relocated to the safe haven of a zoo from abusive circus and logging camp backgrounds, so completely phasing out elephants in zoos appears to be a complex and, for now, unrealistic option. We know that elephants are doing badly in zoos; we will continue to keep them in zoos; so what is being done about it and what more can be done?

Well, since that 2008 report commissioned by DEFRA, much focus has been directed toward developing better welfare assessment tools. This makes sense because after all, how can we improve welfare if we’re still arguing about how to measure it? But, in my humble opinion, this is just another red herring: we already have welfare measurement methods, and whilst it’s good to improve accuracy through every point of contact from governmental inspectors to keepers and everyone inbetween, the spotlight should be on the welfare science: what actively improves welfare for captive elephants – not expanding on existing assessment methods. In UK zoos today, enrichment methods for elephants are often chosen based on anecdotal evidence passed between keepers and zoos, and whilst keeper insight shouldn’t be underestimated, there is a real lack of any quantitative evidence of the difference it makes to welfare. Money and time could instead be spent researching impacts of different enrichment methods in large-scale studies across UK zoos: how does scent introduction affect investigatory behaviour? Are stereotypies most prevalent when visitor density is highest or lowest? True, some enrichment tools have been investigated in other parts of the world in small-scale studies or by university students, but there is a complete lack of consistent empirical study in peer reviewed journals for numerous areas that could improve welfare for elephants across UK zoos and indeed the globe – especially sensory enrichment, if done right.

“You simply cannot say ‘we do great conservation’, but it comes at the expense of the individuals that live in a zoo” – Ron Kagan, CEO Detroit Zoological Society

Though welfare needs vary between captive and wild animals, certain kinds of animals will never be well suited to captivity due to inherent drives that we are simply unable to facilitate – elephants are migratory animals, and we will never be able to give them the ‘ideal’ amount of space. There is a surprising lack of data focusing on the direct relationship between enclosure size and welfare for elephants, but this has been vastly studied across other species and results suggest as you might expect: larger enclosures reduce stereotypies and increase behavioural repertoire, whilst smaller enclosures induce stress, stereotypies and even impaired immune functioning – among other bad things. An influential study in 2001 found that average home range size in the wild is positively correlated with stereotypic behaviour in captivity: aka, animals that roam the most do the worst when confined in a zoo. Interestingly, one large-scale study on zoo elephants says social complexity and sensory enrichment are actually more effective in enhancing welfare than larger enclosures, and there are plenty of other studies supporting the importance of social and spatial complexity to elephant welfare. A logical mind would conclude a mix of all factors proven to positively impact welfare should be used, but as zoos will tend to only provide what is stipulated as absolutely necessary or ‘strongly recommended’ in welfare guidelines (due to £££), there needs to be a lot more research done if we are ever to determine mandatory welfare standards that actually work.

Food for thought – although taking a somewhat anti-zoo stance, this is a very inspiring talk on the morality of zoos and presents some good insights on zoo ethics. Makes you think!

The Legal Stuff: How Exactly Are Zoos Regulated?

Since the UK Zoo Licensing Act in 1981, it is illegal to operate a zoo or aquarium without a valid zoo licence; this licence is valid for 6 years at a time and attractions are inspected every 3 years involving government appointed inspectors, as well as one informal inspection every year by local authority. The Animal Plant and Health Agency (APHA – part of DEFRA) has a ‘Zoos Inspectorate’, whereby Secretary of State inspectors are listed and maintained (typically vets, but also anyone else deemed suitable nominated by the SoS or requested by local authority). By law, formal inspections must have at least 1 or more SoS inspectors present. But, it is the local authority’s prerogative to arrange inspections and decide whether to act upon an inspector’s recommendations or conditions. For example: a SoS inspector might deem a zoo’s welfare provision for their captive elephants unacceptable, and stipulate that the zoo has 3 years to change X Y Z or lose its licence – but it is the local authorities decision whether to enforce this or not via Direction Order (written formal deadline to meet license conditions). Except in Scotland – where Scottish ministers can direct the local authority to attach conditions to the license, and they have to do so. It’s all rather complicated and bureaucratic, but that’s the gist of it. (If you’d like to go even deeper down the legislative rabbit hole, click here).

Is This Regulation Process Working?

Currently, there are real concerns about the many holes in this inspection process – as clarified in detail by this report. In short: accuracy is reduced because zoos are given 28 days notice to prepare; inspections can be biased because the same zoo inspector can conduct the subsequent assessments; applications of criterion vary between different inspectors for the same zoos, suggesting inconsistent assessment methods; competent investigator figures are ultimately decided by the SoS; inspectors do not inspect every animal in a zoo; welfare assessments do not include inspection of all husbandry routines … the list goes on. An unbelievably shocking review of 2005 – 2008 inspections found that only 59% of local authorities followed procedure and sent completed inspection reports to DEFRA. It also found 12 zoos (twelve!) were inspected on the same day, by the same inspector! This is extremely worrying as it shows inspectors are able to cut corners, and the inspection process itself can be more about shaking hands and ticking boxes than actually assessing welfare.

We would all like to believe zoo horror stories happen in other countries, not in the UK – we’re a developed country after all, we have rules and regulations to prevent that sort of thing.. right? Unfortunately, for all our procedures and protocols, animals appear to have slipped through the cracks and every so often an appalling find will be made and a licence rejected; like this infamous safari park in England – in 2017! Licence conditions were applied and the park never actually closed; owners changed hands, there were a couple of successive rocky inspections, and as of 2020 inspectors are now satisfied with the turnaround – commending the zoo for “considerable efforts”.

Licence rejection clearly scared the owners into improving welfare, but given the severity of historical conditions this must be taken with a pinch of salt – just how improved is it, and will things gradually slip back into bad management habits? Only time will tell, but this case highlights both a success and a failing of governmental inspections – on one hand, the regulation process has changed an awful zoo into an acceptable one in just 3 years. But, it also allowed standards to become that awful in the first place. Naysayers will clamour that this is extremely rare, one bad apple cannot reflect the entire inspection process, but one has to ask… how were things able to get so bad there in the first place? UK zoo inspections can be extremely effective, as seen with this park’s turnaround, but undoubtedly need drastically tightened up. Unfortunately, enacting any kind of legislative change takes time … a lot of it. Changing this bureaucratic inspection system will be a lengthy process, so perhaps a faster route to improving elephant welfare can be taken through changing current zoo practice and welfare guidelines – and to do that, a prominent body needs to step up.

African elephant (Africana loxodonta)












Asian elephant (Elephas maximus)


















*Since a detailed genetic study in 2010, a third distinct elephant species has been confirmed: the African forest elephant (Loxodonta cyclosis). (As opposed to the well-known African savanna elephant pictured above). This elephant is only found in the rainforests of Central and West Africa, and looks similar to Loxodonta africana – but smaller, and with more oval shaped ears.

What is BIAZA?

BIAZA is the British and Irish Association of Zoos and Aquariums – a professional body which regulates and inspects welfare in much of our zoos. To be a zoo (or aquarium), you must have a license: but don’t need to be a member of BIAZA. BIAZA is a registered charity and really an independent body, though they work closely with the government (and other prominent bodies like IUCN, EAZA, WAZA). A good proportion of zoos / aquariums are members, or strive to be: because BIAZA is considered the ‘gold star’ of welfare standards – it’s kind of like being in the ‘VIP area’ of zoo-keeping. To be a BIAZA member, you don’t just have to comply to their policies on welfare, you have to continually prove your establishment is contributing somehow to research, conservation, education or animal welfare. They currently have about 100 members across the UK and Ireland – it is estimated there are around 300 zoos / aquariums in the UK, excluding Ireland. (The government has not created a central database listing licensed UK zoos / aquariums, so experts have to guestimate).

Where Do BIAZA Fit In?

BIAZA’s influence is far-reaching and it has played a pivotal role in shaping the landscape of zoo welfare standards. Since 2010, BIAZA has been coordinating the EWG (Elephant Welfare Group), under direction from Lord Gardiner (the Parliamentary Under-Secretary of State for Rural Affairs and Biosecurity), which is investigating evidence based improvements in UK elephant care. The mid-term report was published in 2016, so we should be expecting the final governmental review pretty soon. You can find a link to read the executive summary of what this group is working on here. The minimum standards of animal welfare that UK zoos are expected to meet are laid out in the Secretary of State’s Modern Zoo Practice, which is supplemented by the Zoos Expert Committee Handbook, last updated by DEFRA in 2012. In the former, zoos and inspectors are instructed by the government to consult BIAZA’s separate Management Guidelines on keeping elephants; so it’s really the BIAZA guidelines that need to be advanced if welfare is to be improved. BIAZA also co-ordinates many aspects of the governmental standards, and DEFRA places much trust in the group. Overall, BIAZA has its fingers in a lot of pies – it has access to academia, welfare organisations, zoos and governments, and as a consequence has been able to develop what are often considered the holy grail of welfare standards. But, as poor welfare continues to be evidenced in elephants across the nation (and indeed worldwide), the question has to be asked: why are they not good enough, and how can they be improved?

What Are The Current Welfare Guidelines?

The BIAZA guidelines give an exhaustive amount of background information and research findings, as well as addressing many aspects of welfare practice. This depth is excellent and necessary, however it’s also easy to get lost in the sea of knowledge presented – there is no clear-cut checklist for important areas of welfare standards for zoos to follow, like enrichment, meaning standards can be left open to a degree of interpretation. There are many reasons for this, one being that animal behaviour and welfare is a relatively new scientific discipline in its own right: to put things into perspective, the world’s first Professor of Animal Welfare was appointed by Cambridge University in as recent as 1986 – not even forty years ago. These BIAZA guidelines have only existed from 2002, were refreshed in 2006 and the third edition in 2010 (this blog cannot find any superseding edition).

Let’s look at what BIAZA guidelines say about key areas like Social contact, Enclosure design and Enrichment:

Social Contact: Is recognised as vitally important, and guidelines state that matriarchal groups of at least 4 related cows (female elephants) is the ideal goal – but is not mandatory. If zoos do not keep this many elephants, or keep unrelated elephants (for example Belfast Zoo which has stopped breeding and instead keeps just 2 rescue cases – unrelated, older ‘problem’ females from circus / logging camp backgrounds), they should allow their cows unrestricted access to each other for at least 16hrs in any 24hr period. Bulls (male elephants) are a bit different, as they can pose problems of aggression – guidelines state bulls should run with the herd whenever possible but should also be isolated when necessary, and individual management regimes should be assessed every 6 months to best decide when and how to socialise the bulls. All in all, this seems pretty reasonable.

Enclosure Design: Indoor and outdoor accommodation should be provided and elephants should be allowed access to both without fail, 24hrs a day – elephants should be able to choose where they spend their time. Whether zoos actually provide this or not will never be known to inspectors, who only see the daily routines that zoos choose to present to them. Unless surprise or undercover inspections take place, inspectors will never know if on the other 364 days of the year elephants are denied access to the indoor enclosure – rain, hail or snow. Why would some zoos choose to do this? Answers are plentiful – fear of aggression between elephants in the close proximity of the indoor space? To give visitors a better view? Reasons for denying indoor access will never publicly be recognised by zoos as this is of course a breach of welfare standards, but worryingly this happens in some zoos across the nation. In these instances nothing can be done but trust that keepers are doing what is best for the elephants – but this then leads to obvious failings in outdoor enclosure provisions, i.e. shelter from the weather.

Shelter areas are not specified, described only as ‘sufficient to protect from extreme sunlight, wind and rain’. Who decides what is sufficient? Does a single tree count as shelter? Or a couple of trees on a raised surface, aesthetically pleasing but arguably impractical as animals cannot stand close to the trunk, getting shelter from only the sparse outer branches? What about an open corner from two adjacent walls? As numerous zoos across the UK do not provide any kind of effective shelter in outdoor enclosures, this general description is a loophole. Similarly, guidelines say elephants should have access to a pool, mud wallow and/or dust bathes – numerous zoos provide only sand, or a small sad puddle of mud barely large enough for a single adult elephant. These guidelines do not strictly enforce the need for water bodies, leaving it up to zoo owners to decide how much money and effort they want to put into the enclosure. Chester Zoo is an example of an elephant enclosure with excellent provisions, expanding on sand substrate to include a pool and waterfall structure as pictured below. The same issue can be said for space allowance – the current minimum space allowance for elephants in UK zoos is 200 square metres for 4 or less elephants (indoors) and 2000 square metres for 8 or less (outdoors). Some believe this minimum requirement isn’t nearly large enough, and even with this small space allowance some of our current zoo enclosures fall short of these measurements. Anyone can see the standard failings in enclosure requirements across numerous zoos today – it only takes a quick look on Google Earth to evidence this.

Why is this still allowed? Well, in addition to guidelines that are too general, the big problem here is that although welfare standards have advanced, current elephant enclosures are remnants from the past – having originally been built many decades ago, when welfare provisions weren’t as strict (or indeed existed sufficiently at all). These old enclosures do not have such facilities. So what are these zoos to do? Landscaping existing facilities will cost both time and money, not to mention the tricky question of what to do with the existing elephants during all this as transporting and temporarily relocating is extremely stressful for the animals. Pessimists will say it’s too late and too bad for these elephants – they’ll just have to make do with substandard enclosures. There is simply no other way around it. Optimists will point out that great feats of engineering are routinely done by the human race in record time – if it’s deemed important enough (E.G. the panic hospital built in Wuhan to combat Covid19. It is 645,000 square feet and was completed in 10 days – what’s a small pool or waterfall structure compared to this?). Realists, on the other hand, will say governments value human lives over animal welfare, and we simply don’t have 7,500 labourers to throw at a zoo enclosure (let alone the money to do so). But maybe it’s time to think about phasing out elephants in these particular zoos that just aren’t built to.. well, house elephants? Unfortunately, there is no black and white answer to this dilemma.

Enrichment: Enrichment does not even have it’s own section in the UK government guidelines – merely stating that ‘extensive and varied enrichment should be provided in inside and outside environments and included as part of the daily routine’. Keepers could throw an old sock into the paddock once a week and claim it counts as enrichment through olfactory and tactile stimulation! Enrichment is recognised by leading experts in the field of animal behaviour and welfare as one of if not the most important aspect of captive welfare – and UK government guidelines completely skim over it. How can we expect to improve welfare for our elephants if this isn’t even properly included in the SoS Standards? Zoo Keepers are undeniably passionate about their animals and want the best for them, but are only able to work with what they are given. Many keepers sacrifice their own time and money to pick up novel treats for their elephants – bubbles, scents, objects to hide food in etc – which otherwise would not be provided, and the impacts of many of these things upon welfare have not been adequately researched, or indeed studied at all. So what does the voice of reason (BIAZA) say about necessary enrichment? Enrichment provision seems to have been sprinkled throughout aspects of other sections – food provision, enclosure substrates, enclosure structures, social access. As well as this, BIAZA has a pretty thorough section called An Enriched Environment (skip to pg 77 if you’d like to have a look), where they list all the general bases enrichment forms should touch – like control/choice, food presentation, enabling a large behavioural repertoire, unpredictable positive stimuli etc etc.

BIAZA’s enrichment guidelines are extensive – so why do experts say without a doubt UK elephants indicate signs of poor welfare? Perhaps the answer lies, again, in the inspection process and its generalist approach to welfare. Example zoo inspection forms can be found here and here. If you look over them, you will see 90% of the form is dedicated to traditional indicators of welfare – Food/Water provisions; physical environment provisions like heat, light, and ventilation, and physical health care. The rest of the form is concerned with public safety, transportation of live animals, conservation, animal records and the like. There is no section of the form dedicated to adequate enrichment provision. Only two boxes in separate sections can be said to address this, in roundabout ways. Section 2.1: “Are the animals provided with an environment well adapted to meet the physical, psychological and social needs of the species to which they belong?”, and section 4.1: “Do the accommodation and management regimes encourage normal behaviour patterns and minimise any abnormal behaviour, taking into account the current enrichment and husbandry guidelines?”. Generalist questions can be answered in generalist ways, and ultimately rely on the dedication of the individual inspector. Despite a multitude of guidance on enrichment provided by BIAZA, such inspection criteria enables zoos to get away with the bare minimum of enrichment provisions – like solely relying on novel feed provision and physical substrates. Perhaps variation is the key, and a better approach could include a section dedicated to enrichment – including separate boxes for all BIAZA’s suggestions instead of a one-size-fits-all box, increasing accountability and no longer allowing zoos to rely simply on food provision and appropriate substrates?

‘We should only have animals that can thrive in our zoo environments. Unless an animal can thrive in our environment, whether it’s climate or space or social dynamics, we shouldn’t do it.’

What Is The Future of Elephant Welfare?

This article has aimed to provide a brief overview of the topic – but as you’ve seen (if you’ve stuck with me thus far), the problem is a complex one due to its multi-faceted nature. Major aspects hindering welfare seem to lie within the inspection process and generalist guidelines. Though we do not yet have the magic formula for amazing zoo elephant welfare, we do have a substantial amount of data proven to improve it. If these animal welfare requirements were as strictly regimented as say disability benefits or bank loans, perhaps the zoo world would not be faced with the difficult question; should elephants no longer reside within our man-made constructs? The EWG is nearly finished its 10 year research into ways to improve welfare for UK elephants. Currently, this is the only long-term research project commissioned by the government and is a response to the damning 2008 report. Behaviour and Abnormal Behaviour is 1 of the 5 areas being investigated – including looking at different enrichment resources, and assessing how important they are. If welfare for UK elephants is ever to improve, so too does the minimum standards of enrichment provision – perhaps following the publication of this report, we can begin to make progress, albeit slowly. If in another 10 years time poor welfare is still evident, we have to ask ourselves: how much longer will we subject captive elephants to substandard living conditions, in the hope that one day we can make things better?

Read More:


http://www.zoocheck.com/wp-content/uploads/2015/04/2008-study-of-elephant-welfare-in-UK-zoos.pdf
https://www.researchgate.net/publication/326815989_A_review_of_current_indicators_of_welfare_in_captive_elephants_Loxodonta_africana_and_Elephas_maximus
https://www.zawec.org/en/fact-sheets/44-stereotypies-as-animal-welfare-indicators
https://www.ncbi.nlm.nih.gov/pmc/articles/PMC4494370/
https://biaza.org.uk/news/detail/biaza-position-statement-on-zoo-licensing-and-inspections-in-the-united-kingdom
http://www.legislation.gov.uk/ukpga/1981/37#commentary-key-77c5fa9607c64ac4f60cc943eaeb2ecdE+Wv00012
https://www.gov.uk/guidance/keeping-zoo-animals#zoo-inspections
https://www.idausa.org/wp-content/uploads/2013/05/U-of-Bristol-Report.pdf
https://www.mdpi.com/2076-2615/2/4/507/htm
http://www.zoocheck.com/wp-content/uploads/2015/04/2008-study-of-elephant-welfare-in-UK-zoos.pdf
https://www.sciencedirect.com/science/article/abs/pii/S0168159113000129


Frustrated some papers aren’t free? Don’t copy and paste the article’s DOI link (found at the top under the title) into SciHub. SciHub is technically an illegal ‘pirate’ site that believes access to science should be available for everyone, not just the more economically privileged. This blog definitely doesn’t advise using this pop-up / virus free site to access free scientific papers… The SciHub domain changes frequently but the current one is Sci-Hub.tw. Don’t do it.

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