Monday, December 12, 2011

Report on WSDA Health Certificates Hearing

**Note: The deadline for written comments submitted to WSDA to be included in this hearing is 5PM Pacific Time today, Dec 12, 2011.**

One of our community members attended the hearing in Olympia today. Here is their report:

I appreciated the opportunity to attend the hearing today to ask questions, listen, learn, and give testimony. I shared the concerns laid out in the previous blog post, and was able to get answers to some of my questions from Dr. Eldridge, the state veterinarian with the WSDA.

First, regarding the question of what address should go on the health certificate if an animal is being sold at a show, farmer's market, or other location where the buyer and final destination may or may not be known. I was told that in this situation, the address of the show, market, etc would be what would be put on the health certificate.

More than one address can be put on a health certificate, so if you are attending several different shows or other events in a given month, you would have the veterinarian writing the health certificate put all the locations you intended to take the animal in the next 30 days on one health certificate. I am not sure how this would work for someone who had a pet being used for animal assisted therapy or going with them to visit family, when all the destinations were not known 30 days in advance.

There are some situations where animals such as large livestock require entry permits (different from a health certificate), especially if they are in a class that meets exemptions from some entry requirements.

I asked how long an animal has to remain at the destination on the health certificate, and was told that basically as long as the entry requirements (any required vaccines, inspections, etc) have been met, where the animal goes or what happens to it after it arrives at the destination on the health certificate is not of concern. It can immediately be sold or transferred elsewhere as long as it is healthy and has entered the state properly.

So theoretically an animal could be delivered to a temporary location on the health certificate, and then taken to a different location not on the health certificate that same day, as long as they have met entry requirements such as any required vaccines, testing, etc.

Regarding the concerns about giving one's home address to a stranger when purchasing, being given or rescuing an animal, Dr. Eldridge had an interesting suggestion for handling that. He said that if your veterinarian is willing, they might allow your veterinarian's address to be given as the destination address, as long as the veterinarian knows how to get hold of you. Or, if you have a specific situation or concern come up, you can contact the WSDA and they will help you figure out how to handle it, or may allow an exception to some rules depending on the situation.

He reiterated several times that their goal is to prevent people from circumventing entry requirements such as required vaccines and testing. As long as any applicable entry requirements have been met, they aren't as concerned about what happens to the animal after it has entered the state.

There was some conversation about how requiring destination addresses on health certificates would assist in quickly tracking down animals after it was discovered they had been exposed to a contagious disease. However, if they had been sold or given to someone else after entering Washington, or moved to another location, they may not be able to be tracked farther.

I asked what would be gained from having the buyer's physical address over simply having the contact information of the veterinarian issuing the health certificate, who would have the contact information for the seller and would likely be able to help track down the buyer if needed. I had a bit of a difficult time understanding the reply, but I think the gist of it was that in a disease outbreak, speed is of the essence, and having the destination address would facilitate faster location of animals that may have been exposed.

The state vet reiterated that the goal of these rules was to help ensure safe, healthy animals and not to make life difficult for people.

++ Of course they aren't sending out staff to stop every car and see if you are smuggling a mouse across state lines, and they are most concerned about livestock and other animals that require testing and vaccines. RCW 16:36:045 indicates that inspections are "with emphasis on livestock being brought in from outside the state." But they *do* legally have the right to stop your vehicle and check for animals that have inappropriately entered the state. The fines and consequences if you do get stopped and they verify that you have brought non-exempted animals into the state without a health certificate are outlined in the law. The animal can be quarantined and tested at your expense, can be euthanized under certain conditions, and you can be subject to fines or other penalties. ++

Basically, they said that this law was enacted to prevent situations like people circumventing entry requirements (i.e. required testing, vaccinations and health certificates) by saying the animals were going to slaughter or a feedlot, but then diverting the shipment so that the animals were not actually sent there. They don't want animals that were exempted from entry requirements because they were supposedly going to slaughter, ending up in production or in situations where they might come into contact with or infect other animals within the state without having gone through appropriate channels for entry into the state.

I sent in a comment suggesting that they focus their rule-making on requiring that animals couldn't be diverted from shipment to circumstances that would require a greater level of entry requirements than the destination on the health certificate, or something like that. Such an approach might effectively keep it limited in scope to what was necessary to achieve the goal of the law.

The deadline for written comments is 5PM today, Pacific Time.

(This post was updated Jan. 7th, 2012 to add/edit the paragraph surrounded by plus symbols ++.)


  1. WELL done, and wish I could have been there. Suggest next step to be a formal written request to exempt rabbits from the requirement in return for the rabbit industry encouraging its members to keep good records of who-went-where-when....after all, there really ARE no vaccines, no required inspections for rabbits as a species, and the only reportable diseases of rabbits are RVHD and myxomatosis--neither of which affect humans or other species.

    We, as responsible stockmen, need to be keeping those records more scrupulously than we are, anyway, so we can improve not only our own standing in excellence, but also help avoid the perceived need for health certs on rabbits entering a state.


  2. While everyone should be keeping records as extensively as they can, keeping a record of which rabbit went where, when, runs into the same problems as requiring an exact physical address on health certificates--someone buying a rabbit may be hesitant to give their home address to the seller.

    I would, however, like to see the rabbit community in dialog about how to allay any health concerns in a more financially viable way.

    When the cost of meeting entry requirements to bring an animal into the state exceeds the value of the animal, it is difficult to justify in a reasonable cost/benefit analysis when the risks of that species are so incredibly low. Especially in a case such as rabbits, where the diseases they can carry don't affect humans or other animals, there are no vaccine or testing requirements, and a veterinary exam is not likely to find anything that a careful examination by a buyer or experienced breeder wouldn't bring to light.