Sunday, December 11, 2011

Hearing Regarding Addresses on Health Certificates

On Monday morning 12/12/2011 at 9AM, WSDA is holding a hearing at the Natural Resources Building in Olympia, WA regarding how, when, and for what species of animals to implement the new rules for having the exact destination address on health certificates for animals entering Washington.

Details here:
http://agr.wa.gov/LawsRules/Rulemaking/AH/AnimalImportationCurrentRulemaking.aspx

CR-102 has the address and details about the hearing, and also information about how to submit written comments.

It is worth noting that this particular law applies to anyone who may ever visit or sell an animal to anyone in Washington, even if you do not live in Washington State yourself.

WSDA's website says, about these hearings:

"Accepting public comments: Anyone may go to public hearings to testify about WSDA proposed permanent rules, offer written comments, or just listen. WSDA hearings are held around the state depending upon the rule's subject matter. For those who can't attend a hearing, sending written comments is just as effective."

The rule was made to prevent things like shipments of cattle being diverted to a different address than where they were supposed to be delivered. However, the law itself is much broader and applies to all animals with no exceptions. WSDA's role is to define when, in what situations and for what types of animals to apply this law.

    Here are some of our concerns with this new rule and its possible unintended consequences: 

  • Safety for the citizens of Washington. It is usually advised that when doing transactions via Craigslist, Freecycle, newspaper ads, or dealing with anyone not known and trusted, the transaction take place in a neutral public location. This is to avoid either the buyer or the seller having to give their personal information and home address to the other, as well as to keep the meeting in a place where other people are around in case one person turns out to be dangerous.

    If the exact destination address is required, this would mean that the Washington resident is required to give their home address to the person they are getting an animal from. This could be particularly uncomfortable and dangerous in cases such as a private party doing an unofficial rescue. Giving one's home address to someone who is surrendering a neglected or abused animal is not the wisest or safest thing to do. Neither would most people want to have to give their home address to everyone giving away free chickens or selling meat goats.

  • The potential impact on the showing community, and anyone who frequently visits the state with their animals. The cost of a veterinary exam and health certificate already exceeds the value of many small animals and poultry. If owners had to get a separate health certificate for each show or other event they attended, rather than getting one health certificate every 30 days as the law previously allowed, the cost would quickly become prohibitive to attend shows. While some animals (such as llamas, goats, cats and dogs) already have exemptions in the WAC 16-64 rules for brief round-trip visits, many species of animals--including several species of small animals that commonly compete in shows--are not currently covered by such exemptions.

  • The impact on buying and selling animals when the purchaser is not known in advance. It is very common for people to offer animals for sale at shows, fairs, auctions, livestock markets, farmer's markets and other events. If the final destination address is required on health certificates, how would that work when the animal is being transported to a temporary location and offered for sale? The potential buyer and the final location would be unknown at the time the health certificate was acquired.

  • Relocation ability. How long would an animal be required to stay at the location listed on the health certificate before moving to another location? What if the owner decides to sell or give away the animal, move the animal from their ranch to their home or vice versa, or the owner moves to a different location and wants to take the animal with them?

  • Rescues and shelters. Rescues and shelters often bring in animals to Washington and then distribute them to foster homes or adopters. How would this rule impact the ability to bring in a needy animal to a temporary location in the state while the needed homes or foster homes are found? 

While we can certainly understand the reasoning behind this new law, we do hope that the WSDA will make rules that accomplish that purpose while avoiding unintended consequences that could deter people from showing, buying and selling animals, or that could even place Washington residents in unnecessary danger.

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