Thursday, June 21, 2012

Buying animals at shows


[To understand a bit about ARBA shows, see the trailer for the movie Rabbit Fever here: http://www.rabbitfever.com/trailer/ ]

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Rabbits and cavies are often sold at sanctioned ARBA shows.

This has many advantages for both buyer and the seller: It's a safe environment with many people around; it doesn't bring strangers to the breeder's home to endanger their family, possessions and animals; and it doesn't compromise herd biosecurity.

Most importantly, it allows the buyer an opportunity to get  expert second opinions on the health and quality of the animal. Other breeders and judges routinely look over rabbits/cavies for potential buyers. It's common to see multiple breeders and/or judges helping a buyer make a purchasing decision at a show. It's also quite common for someone who lives a long distance away or can't make it to the show to ask a trusted friend to inspect and choose animals for them. This would no longer be allowed if the new USDA rule passes, unless the seller was USDA licensed.

(Remember, the AWA standards for licensed breeders require that animals be raised in a sterile environment with restrictions designed for laboratories and large commercial facilities--impossible for hobby breeders or family farms to meet, and preventing animals from being raised in a typical home/family environment.)

An unhealthy or poorly cared for rabbit/cavy is readily apparent by examining the animal itself; with a careful and knowledgeable inspection one does not need to see where they were raised. Most breeders also guarantee the health of the rabbit for at least a few days after purchase. Since the show world is a very small and tight-knit community, simply asking around about a breeder's reputation will quickly tell you who to buy from or avoid.

This rule would remove a very important safeguard for buyers.

Please allow consumers to choose shows, competitions and other offsite ways to buy animals, without forcing USDA licensing. We do not need a nanny government to protect us from the freedom to make our own informed purchasing decisions. We're perfectly capable of thinking for ourselves.

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This is the comment we submitted today. 

Animal Welfare; Retail Pet Stores and Licensing Exemptions


Agency: APHIS 
Document ID: APHIS-2011-0003-0001
Your Comment Tracking Number: 8105dab3




Submit your comment to APHIS here: http://www.regulations.gov/#!documentDetail;D=APHIS-2011-0003-0001

Don't forget to also contact your congressional representatives!

You can also call Jerry Rushing, the staff vet for the Animal Care Department. His phone number is (301) 851-3735.

Tuesday, June 19, 2012

A couple of new things about us . . .


We are changing our name from Washington State Animal Watch to Washington Animal Watch to reflect the fact that we follow federal (Washington D.C.) issues as well as just Washington State. Both federal and state laws and rules will impact Washingtonians, so it's important that we cover both types of issues.

Of course, if you are not a Washington resident but may visit or ship animals to WA, you will also want to follow our posts.

Washington Animal Watch now has a Facebook page! You can "like" our page for updates and to share our photos more easily. https://www.facebook.com/waanimal

Sunday, June 17, 2012

Images Opposing PUPS and the APHIS proposal

These images are free to repost on your own site, provided that you do not edit or change them (making the file size smaller without altering the image itself is fine). You must leave the text intact.

Check back; more images will be added to this post over the next few days.

We also wish to clarify that we are not against commercial facilities for raising animals. We are against taking away the CHOICE for breeders to use any humane method of animal husbandry, including raising animals in a home environment.













You can click on any of these photos to view and download a larger version. To post on Facebook, just go to our page at http://www.facebook.com/waanimal to find the image you like, and click "share."

Suggested text to publish alongside, for the ones that don't include as many details in the image itself:

The proposed new USDA/APHIS rule and PUPS law would prevent most animals from being raised in a home and family setting. The Animal Welfare Act limits licensed breeders to only commercial/laboratory style settings. 


Allow farmers, breeders, show competitors, hatcheries, working/service animal producers, shelters and rescues to choose any humane method that works for them, their animals and their goals. Please oppose PUPS legislation and the APHIS-2011-0003-0001 proposed rule, "Animal Welfare; Retail Pet Stores and Licensing Exemptions."  
For more information, see http://waanimal.weebly.com/aphis.html 
or, 
APHIS 2011-0003 applies to "Dogs, cats, rabbits, guinea pigs, hamsters, gerbils, rats, mice, gophers, chinchilla, domestic ferrets, domestic farm animals, birds, and cold-blooded species." PUPS applies to dogs.

Both would greatly restrict the ability to raise pets in home and family farm settings.
 
For more information, see http://waanimal.weebly.com/aphis.html 




With any of these images, you may also wish to include a link to our post, "Why not just apply for a USDA license?" http://waanimal.blogspot.com/2012/06/why-not-just-apply-for-usda-license.html


And/or, "New USDA rule would force small breeders to become licensed." http://waanimal.blogspot.com/2012/06/new-usda-rule-would-force-millions-of.html 



Or, here is an excellent site which combines all the most important links in one place: STOP the proposed APHIS RULE in 3 Easy Steps! http://www.icontact-archive.com/sRszqmyZGmERhv5PQPZvnX-eSvbsTRM0?w=2



* Note: All photos are either royalty-free pictures from online libraries that are labeled free to use for this type of purpose, are purchased with a license that allows this type of use, or are used by permission of the owners.




Saturday, June 16, 2012

New USDA rule would force small breeders to become licensed.


The proposed federal APHIS/USDA rule which is being falsely touted as an "anti-puppymill" rule actually applies to "Dogs, cats, rabbits, guinea pigs, hamsters, gerbils, rats, mice, gophers, chinchilla, domestic ferrets, domestic farm animals, birds, and cold-blooded species."

From the proposed rule:
In addition to retail pet stores, the proposed rule would exempt  from regulation anyone who sells or negotiates the sale or purchase of any animal, except wild or exotic animals, dogs, or cats, and who derives no more than $500 gross income from the sale of such animals. In addition, the proposed rule would increase from three to four the number of breeding female dogs, cats, and/or small exotic or wild mammals that a person may maintain on his or her premises and be exempt from licensing and inspection if he or she sells only the offspring of those animals born and raised on his or her premises for use as pets or exhibition, regardless of whether those animals are sold at retail or wholesale.


In other words, if you own or co-own more than 4 breedable females (of any combination of cats, dogs or exotic animals) and sell pets (or animals for exhibition--which can include something as simple as using an animal in a photo promoting a product--or any other USDA-regulated animals), sell any animals not born and raised on your premises as pets, sell more than $500 worth of AWA-regulated animals (gross, not profit), or sell even one animal as a pet in a transaction in which the buyer does not personally come to your home or place of business, you must be USDA licensed and conform to AWA standards.

Here is a handy chart to help you understand the exemptions (just substitute the word "females" for species other than dogs--it does apply to more than just dogs): http://www.virginiafederation.org/how-will-it-affect-you

This means that people will no longer be able to carefully choose the pet (or the prospective home for their animal) that is the best fit, but will instead be limited by geographic proximity.  

Without being USDA licensed, rescues can no longer adopt animals out of foster homes unless every prospective adopter goes to the foster family's house. It may affect chick hatcheries being able to ship chicks to people who want backyard chickens or ducks as pets. Sales can no longer take place at competitive shows where multiple knowledgeable second opinions about the health and quality of the animal are readily available.

Pets will not be able to be shipped or transported by either a third party or the seller themselves to the prospective buyer, no matter how carefully the buyer and seller (or rescue and adopter) have checked each other out or how well they know each other, or even whether they have already had previous dealings and this is a repeat transaction (and even though animals being shipped are already required to have a certificate from a veterinarian verifying that they are healthy and have had all required vaccines and testing). It will eliminate chains of volunteers forming a "train" to transport a rescue pet or a rare breed across the country.

For a small hobbyist breeder or rescue who keeps their animals in their home with their family, forcing them to bring every prospective buyer or adopter is dangerous for many reasons. 

Bringing all buyers into the home compromises biosecurity and puts the animals at risk from disease--things like parvo, mites, parasites and other issues can easily be carried on visitors' shoes, hands or clothing. It could also compromise the emotional well-being of the animals; as an animal recovering from surgery, giving birth, or in advanced old age could be easily stressed out by strangers coming into their space.

It also opens up both the animals and the homeowner to a substantial risk from thieves, animal rights activists, vandals, and others who may wish them harm.

Forcing a private citizen to bring customers into their home is far more dangerous than having customers come into a business. Farm homes are often remote from other people, out of view from the road or other public areas, and too far from neighbors for anyone to hear calls for help. Emergency services such as fire, medical and police help are farther away and will turn out in smaller force for a residential call than for a business call.

If this rule passes, it will make it far too easy for thieves, rapists, murderers, extremists and other dangerous people to gain access to private homes.

It may also cause issues with city and county code compliance, as many counties allow home businesses in certain districts only as long as customers do not come to the home. Home insurance companies are also likely to drop people's policies or charge far more if customers are coming to the home.

If you're thinking that requiring more people to be licensed and inspected is a good thing, think again. Animal Welfare Act standards were written and intended for laboratories and large commercial enterprises, not small family businesses, rescues, service dog organizations or in-home breeders. A person CANNOT raise animals in a home with a family environment and meet AWA standards.

If someone is USDA licensed, they are required to keep their animals in a sterile commercial-type setting with myriad regulations about things like having impermeable services, specific sizes and types of enclosures, pristine like-new equipment and facilities (even a few hairs on the floor, a spot of rust on an enclosure or a cobweb on the ceiling can be a violation) and not having young animals around any other animal besides their mother. Not to mention the types of records required to be kept, excessive veterinary requirements, and other issues we go into more detail about in our previous post, Why not just apply for a USDA license? 

Remember, this is a federal rule, which means it will apply to all of the USA--not just one state.

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More information and sources:

Here is the link where you can make comments directly to APHIS (as many as you like; you're not limited to just one) on the proposed new rule which would drastically widen the pool of people required to be licensed: http://www.regulations.gov/#!documentDetail;D=APHIS-2011-0003-0001

The Cavalry Group has put up a website with a tool to make it easy to email your congressional representatives about this issue (this is important because the new rule must be approved by Congress). You can use their suggested wording, or (for more impact) revise and edit it to reflect your own situation and wording. (While you're at it, it would also be a good idea to write another note asking them NOT to support the PUPS (Puppy Uniform Protection and Safety) Act, another very similar law backed by the HSUS and other animal supremacy groups that some congressfolks are trying to pass.) http://the-cavalry-group.rallycongress.com/6980/urge-congress-take-action-to-support-cavalry-group-mission/

The AKC also has a petition going: http://www.akc.org/petition/


Here is the site where you can look up inspection reports. You can search by any term, including type of animal. http://acissearch.aphis.usda.gov/LPASearch/faces/CustomerSearch.jspx

And here are the published regulations pertaining to the Animal Welfare Act:
http://www.aphis.usda.gov/animal_welfare/downloads/awr/awr.pdf

Here are a lot of the forms and other info:
http://www.aphis.usda.gov/animal_welfare/pubs_reports.shtml

Washington Animal Watch Posts about the proposed USDA/APHIS rule:

New USDA rule would force small breeders to become licensed. http://waanimal.blogspot.com/2012/06/new-usda-rule-would-force-millions-of.html

Why not just apply for a USDA license? http://waanimal.blogspot.com/2012/06/why-not-just-apply-for-usda-license.html

Images Opposing PUPS and the APHIS proposal (for posting on your own site, Facebook page, etc.) http://waanimal.blogspot.com/2012/06/ads-opposing-pups-and-aphis-proposal.html

Buying Animals at Shows: http://waanimal.blogspot.com/2012/06/buying-animals-at-shows.html

Our thoughts on the APHIS fact sheet and ARBA/APHIS teleconference notes: http://waanimal.blogspot.com/2012/07/never-trust-lawmakers-who-say-they.html

What is a place of business? (be sure to read the comments, too):  http://waanimal.blogspot.com/2012/07/what-is-place-of-business.html


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Copyright Washington Animal Watch, 2012




Please remember that all original works are copyrighted unless otherwise stated, even if they do not carry a copyright notice. You may freely share the link to this page, and brief excerpts (with credit and a link), but republishing an article elsewhere or copying and pasting it to share on newsgroups, websites, etc. is a copyright violation. More importantly, the hyperlinks may not be included and the unauthorized version will not include any more recent corrections or updates.

Wednesday, June 13, 2012

Why not just apply for a USDA license?

Note: This post is about a FEDERAL rule that will affect all of the USA. See our post giving more information about the rule itself and who it will apply to: New USDA rule would force small breeders to become licensed. 

With the current APHIS rule up for comment which would make almost every breeder, rescue and farmer subject to Animal Welfare Act (AWA) requirements and USDA licensing, many are asking, "Why not just get a USDA license?"

The AWA requirements may make sense for laboratories and large commercial facilities. The problem is that the license requirements are so extensive, costly and restrictive that virtually no small hobby breeder, rescue, service dog raiser or family farmer will be able to comply with them.

While I believe people should have the option to become USDA licensed if they wish, I do not feel it is appropriate to force small breeders, hobbyists, show competitors and family farmers to become USDA licensed and inspected. 

Many people don't realize that AWA standards require that all animals be raised in a sterile commercial-style facility. The rules are designed for laboratories, commercial facilities and large scale operations--not for a family farm, small rescue, foster home or hobbyist breeder.


You CANNOT raise animals in your home in a family environment and meet USDA licensing requirements. For instance, all surfaces in contact with animals must be impermeable and sterilizable. That means no carpeting, no unsealed wood, no soft bedding, no sofa or bed in the area your animals are raised.

No more well-socialized puppies or kittens being raised in a home with a family and routine exposure to various people, pets, appliances and other normal household goings-on. No more young animals learning manners from or learning to interact with other animals in the household, because generally baby animals in USDA licensed facilities must be kept apart from all animals other than their mother and littermates.

If you go to the USDA website you can read inspection reports. Here is the link. http://acissearch.aphis.usda.gov/LPASearch/faces/CustomerSearch.jspx

A violation can result in consequences including warnings, having your license suspended or revoked, and/or a monetary fine of up to $10,000 per animal per day. This isn't necessarily determined by the severity of the offense. For instance, the Dollarhite family faced extreme penalties (a more than $90,000 fine, which was a "discounted" penalty from the nearly 4 million dollars calculated to be the maximum possible penalty) because they did not have the required license to sell more than $500 gross in rabbits and cavies to a pet store. This was not about animal welfare violations, but simply about the lack of a USDA license.

Another family was told that they would be fined $10,000 because they were leaving for a family funeral when the APHIS inspector arrived, and it was cited as an Animal Welfare Act violation when they wouldn't skip the funeral to accommodate the surprise inspection.


Not only does USDA licensing open you up to violations of your privacy and your 4th Amendment rights with inspectors in your home, but also in the public sector.

Inspection reports are posted online. This means that your name, address, number and type of animals, and other details about your operation are posted online in publicly accessible locations. Especially for people who raise animals at their residence, this can put breeders at risk from thieves, animal rights activists, and others who might wish to steal from or harm them.

In order to have a USDA license, you must:

1. Have a responsible adult who can explain your operations available every weekday during business hours (defined as 7AM to 7PM) to accommodate surprise USDA inspections. If they come for an inspection while you are gone due to an errand or emergency, you will be written up for a violation. This means you must hire someone to be present EVERY TIME you must leave home during business hours. This is completely impractical for small farms, hobby breeders, and rescues that use foster homes.

2. Obtain animals only from USDA licensed facilities or those that can prove they are exempt. The records you must maintain are extensive, including the name, address, driver's license number, and make/model/license plate of vehicle of people you obtain animals from; as well as detailed records about the animals themselves. These records must be kept on the premises and available for inspection at all times. See the form here: http://www.aphis.usda.gov/animal_welfare/downloads/forms/aph7020.pdf
(The form makes it sound like you only have to get the vehicle/DL info. on commercial drivers, but if you read the inspection reports they expect you to maintain this information for anyone who is not USDA licensed).

3. Have pristine laboratory-style equipment and facilities in essentially brand new, perfect condition. No animals in your home, as previously mentioned--homes have permeable surfaces like carpeting and wood.

All surfaces must be impermeable, flawless and able to be completely and regularly sterilized. Nothing that could conceivably injure an animal under any stretch of the imagination. Nothing that could conceivably attract or harbor pests. Lighting, climate control, water and electrical access, and wash facilities and methods all must meet specific requirements.

Depending on the inspector you happen to get, the slightest amount of dirt or soiling may be unacceptable. Something that one inspector deems acceptable, the next inspector may write up as a violation. The guidelines are vague and extensive enough that an inspector can always find a violation of some sort if they want to, no matter how well kept your animals and how clean your facility.

    Sample citations on record in this category, from actual inspection reports:

  • A barn with no sink installed. Lack of climate control, and/or the temperature, humidity, etc. being outside the required narrow range. Cracks, rough edges or gaps on surfaces, even surfaces not directly in contact with animals. Wood surfaces, especially if unsealed or showing any signs of wear or chewing. Unsealed concrete, even if not in contact with animals. Rust on any surface, including the outsides of animal enclosures.

  • Metal urine guards in cages. Wire floors with gaps large enough for toes or baby animal feet to go through at all (basically all wire floors could fall into this category, even for species such as rabbits where wire floors are standard and supported by scientific research as appropriate). One to six inches of feces on the ground underneath hanging rabbit cages, despite noted lack of odor. Bags of manure outside a barn.

  • Sterilizing equipment with a bleach solution (bleach alone is not an approved method).

  • Weeds or tall grass in the yard outside the building. Dust on an object that was not inside any animal enclosure. Cobwebs on a ceiling. Exposed nail heads and/or insulation in the building. Anything not immediately needed for the care of the animals anywhere in the general area (even if not inside animal enclosures). Animal hair on the floor.

  • Open containers of hay, lime or feed. Staining, soiling or holes on/in walls behind (not in) cages. Unlabeled containers. A door (not to enclosures confining animals, but to the building) left ajar. Open garbage cans. Empty feed bags. Full feed bags, opened or unopened, stored in the area.
Those are just a few examples. I recommend that you read through the reports with cited violations to get a fuller picture.

The takeaway for me is that the vast majority of "AWA violations" cited are not the type of thing most people would think of when they consider animal abuse and neglect--at least not in isolation as a minor occurrence. And yet each item listed here could potentially carry a penalty of up to $10,000 per day for each animal affected.


4. Have a veterinarian on staff or on call and regularly attending the animals in your facility. Not just as needed or for occasional checks, but the veterinarian is required to be supervising and having authority over everything. The vet does not have to be the one doing daily inspections, but is supposed to be in charge of the animals' health in your facility.

My vet charges a $30 farm call fee, on top of his normal fee which is a $75 minimum for up to the first half hour and then I think it was $130 per hour after that. That is not including any supplies, procedures, etc. So I'm at a minimum of over $100 every time the vet is called in.

One of the violations cited in an APHIS facility inspection was that there was a rabbit with what sounded like wry neck when the inspector arrived. The employee was waiting for someone with more authority to arrive to tell them what to do. When the USDA inspector informed them that waiting a short time to do something was not an option and they needed to call the vet, they euthanized the rabbit--something most breeders would agree was an appropriate action for wry neck, as the prognosis for this disease is very poor and it puts other animals at risk. They were then cited for putting the rabbit down without first consulting the vet.

A number of facilities were cited for using standard over-the-counter or home treatments for routine parasite treatment, minor wound care and common non-serious ailments, because the vet hadn't been called in on it--particularly if the specific use was off-label, even if commonly used that way by veterinarians and animal caretakers.

 Minor issues that were being treated with over-the-counter remedies (or that had just occurred and had not yet had time for treatment) were cited as violations, as were issues such as tartar on dog's teeth and a red spot on an animal's paw.

Having expired ointments or medications on the premises--even if you're not actually using them to treat an animal--is a veterinary care violation. Using medications off-label without a prescription is another, even if they are standard treatments for that issue (i.e. using a topical antibiotic cream on a wound for a type of animal not specifically listed on the label, even if a similar type of animal is listed and it is known to be an appropriate treatment for the animal you are dealing with).

So, not only do you have to have normal routine vet checks, you basically have to call the vet in for every little thing, even if all you plan to do is immediately euthanize the sick animal.

Many vets are going to recommend extensive treatments for many things that most breeders would cull a small animal, livestock or meat animal for.

These treatments can be prohibitively expensive and can also interfere with the intended use of the animal. For instance, Baytril, a commonly prescribed antibiotic, is very expensive. I believe it costs about $50 for enough to treat one small (i.e. 4 lb.) critter for one week. Like most medications, it is not approved for use in some types of meat animals, and there is a withdrawl time for others. Other medications are blacklisted so that if that medication is ever used during the life of the animal, it can never be used as meat. It makes no sense to spend thousands of dollars to do surgery on an animal that was intended for slaughter in a few days anyway--most would opt to put the animal down rather than treating it in such a situation.

But if a facility is USDA licensed, you now have a situation where the breeder is no longer free to make decisions about whether to treat or cull based on cost effectiveness or the greater good of the herd, or can vet the animals themselves for standard things every good farmer knows how to treat. The USDA licensed facility must call in the vet for everything.

If the treatment the vet recommends is too expensive and complicated, or you don't feel the prognosis is good enough, or it's a meat animal and you plan to butcher it soon anyway so you opt to slaughter it early rather than dealing with treatments and medication residues, what then? Are you now out of compliance for failing to follow the veterinarian's recommendations?

It's also a complicating factor that for some types of animals, it's very difficult to find a veterinarian that is knowledgeable about the species--and even more so a vet that is familiar with herd or flock management. Veterinarians have been known to do things like prescribe oral amoxicillin for a rabbit with enteritis, despite the owner's protests that it was an inappropriate medication choice for rabbits. Another common occurrence is for vets accustomed to treating pet animals to prescribe medications not appropriate for food animals.

So what are your options then? You're either going to have to pay ANOTHER vet for a second opinion, be out of compliance by not following the vet's advice, or be out of compliance or at least doing something terribly unethical and possibly killing the animal by giving it a medication known to be contraindicated for that species or situation.

Not only could the veterinary requirements alone easily end up costing hundreds or thousands of dollars per month, it could also significantly hamper a breeder's ability to make appropriate decisions for themselves, their business and their animals.


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More information and sources:

Here is the link where you can make comments directly to APHIS (as many as you like; you're not limited to just one) on the proposed new rule which would drastically widen the pool of people required to be licensed: http://www.regulations.gov/#!documentDetail;D=APHIS-2011-0003-0001

The Cavalry Group has put up a website with a tool to make it easy to email your congressional representatives about this issue (this is important because the new rule must be approved by Congress). You can use their suggested wording, or (for more impact) revise and edit it to reflect your own situation and wording. (While you're at it, it would also be a good idea to write another note asking them NOT to support the PUPS (Puppy Uniform Protection and Safety) Act, another very similar law backed by the HSUS and other animal supremacy groups that some congressfolks are trying to pass.) http://the-cavalry-group.rallycongress.com/6980/urge-congress-take-action-to-support-cavalry-group-mission/

The AKC also has a petition going: http://www.akc.org/petition/


Here is the site where you can look up inspection reports. You can search by any term, including type of animal. http://acissearch.aphis.usda.gov/LPASearch/faces/CustomerSearch.jspx

And here are the published regulations pertaining to the Animal Welfare Act:
http://www.aphis.usda.gov/animal_welfare/downloads/awr/awr.pdf

Here are a lot of the forms and other info:
http://www.aphis.usda.gov/animal_welfare/pubs_reports.shtml



Washington Animal Watch Posts about the proposed USDA/APHIS rule:

New USDA rule would force small breeders to become licensed. http://waanimal.blogspot.com/2012/06/new-usda-rule-would-force-millions-of.html

Why not just apply for a USDA license? http://waanimal.blogspot.com/2012/06/why-not-just-apply-for-usda-license.html

Images Opposing PUPS and the APHIS proposal (for posting on your own site, Facebook page, etc.) http://waanimal.blogspot.com/2012/06/ads-opposing-pups-and-aphis-proposal.html

-----------------------

Copyright Washington Animal Watch, 2012


Please remember that all original works are copyrighted unless otherwise stated, even if they do not carry a copyright notice. You may freely share the link to this page, and brief excerpts (with credit and a link), but republishing an article elsewhere or copying and pasting it to share on newsgroups, websites, etc. is a copyright violation.