Information from WA State Veterinarian's Office About Health Certificate Requirements

A concerned citizen wrote to the Washington State Veterinarian's office with some questions about health certificates. Dr. Paul Kohrs, the assistant state veterinarian, was kind enough to reply, and to give his permission for his letters on the topic to be posted publicly. The citizen shared their emails with us and gave permission to reprint them, as well.

The citizen asked if health certificates were required for small animals with little to no health risk coming into the state for a brief visit. They also inquired whether a health check at an event such as a show would meet the requirements and substitute for a health certificate.

They also said,

I called every veterinarian in the phone book in [nearest city across a state line] and found that the average price for a health certificate is $100 for one animal. Most of the clinics would not even do CVIs for animals other than cats and dogs, period--especially small animals like pocket pets. Many also gave little to no discount for multiple animals getting veterinary certificates at once.

This fits with what others who have attempted to obtain health certificates for animals other than cats and dogs have shared with me, also. It is very difficult and expensive to obtain a veterinary certificate, especially for small animals other than cats and dogs, since finding a vet who will even see them is impossible in some locales.

The way the law is written, it appears that even an earthworm would require a health certificate to be brought into the state on a brief visit. (It's fairly common for earthworms to be raised for bait or for redworm composting, and quite possible they could be brought across state lines that way--and earthworms are not insects.)

For small animals like cavies, rabbits, hamsters or earthworms, what is the purpose of requiring a health certificate for things like a brief visit by private conveyance into the state, since there are no testing or vaccines required that need to be verified?

Are there any diseases that would be dangerous to humans or other types of animals that a rabbit, for instance, would be likely to carry? Or any reportable diseases that would not be apparent to a lay person but that a vet would find in a simple examination without running any tests?

I would like to better understand what benefit is gained by this requirement when it is so costly and difficult to fulfill.

How does the state calculate that the benefit/cost analysis works with these types of animals, when the cost of meeting requirements to bring one of these small animals into the state is higher than the cost of replacing a whole herd of them would be? Especially when there is little to no risk to any other species.

If it cost that many times the value of a cow every month just to meet the requirements to bring it across state lines, I imagine that would have a pretty significant impact on the cattle industry.

Thank you again,

---------

Dr. Kohrs' first reply:

Dear _______,

I have been asked to help clarify the meaning and reasoning in developing regulations for the importation of livestock and other animals into the State of Washington. To begin, allow me to repeat what Ms. Jones emphasized in an earlier note;
     The Mission of the Animal Health program is to:

• Protect and enhance animal health and animal well being.


• Promote the economic vitality of the livestock industry by minimizing exposure to animal diseases.
• Safeguard the citizens of Washington State by identifying and limiting the exposure to zoonotic diseases (transfer from animal to human).

To accomplish this mission, rules and regulations need to be developed and administered in what we feel is a fair and equitable manner. The law states that all animals as defined in Chapter 16.36 RCW are members of the animal kingdom, except humans, fish and insects. To develop regulations for each and every species and subspecies of these smaller animals is a monumental task, the scope of which our department has never had the funding or staff for such an endeavor.

In answer to your statement of these small pets being brought into our state by private conveyance for a brief visit, it is true that we do not require a health certificate (also known as a certificate of veterinary inspection; CVI). If, however, the animal is being imported to a fair or show in Washington, or sold, it must be examined by a licensed and accredited veterinarian to assure it is healthy. One must consider that these animals, although small and cuddly, can carry organisms that can cause disease in other animals and humans also.

For example:

• Cavies (gerbils) [sic] can have, carry and transmit mites, lice, ringworm, Salmonella, just to name a few
• Rabbits can have, carry and transmit Pasteurella sp, Bordetella sp, Rabbit diarrhea, Clostridium sp (enterotoxaemia), and Epizootic Rabbit Enteropathy.
• Hamsters can have, carry and transmit Campylobacter sp, Salmonella sp and ringworm.
• Earthworms can carry and transmit Histomonas meleagridis that affects turkeys, chickens and other breeds of poultry.

It should also be remembered that any warm blooded mammal can contract rabies, and although rare, it is still possible for a rabbit or cavy to have the disease.

In regards to what veterinarians charge for a CVI, we have no control of nor can we comment on that, as it is up to each individual veterinary practitioner, clinic or hospital.

If you have further comments, please feel free to contact our office.

Sincerely,

Paul Kohrs, DVM
Washington State Assistant State Veterinarian

The reply from the inquirer, asking for more clarification:

Dear Dr. Kohrs,

Thank you very much for your reply.

Your letter states,

"In answer to your statement of these small pets being brought into our state by private conveyance for a brief visit, it is true that we do not require a health certificate (also known as a certificate of veterinary inspection; CVI). If, however, the animal is being imported to a fair or show in Washington, or sold, it must be examined by a licensed and accredited veterinarian to assure it is healthy."

This states that a small animal being brought into WA by private conveyance for a brief visit does not require a CVI. I had been given to understand that a CVI was required to bring these animals into the state, so I appreciate the clarification.

I am not quite clear on whether you're saying small animals traveling with their owner by private conveyance to attend a show, etc. need a CVI, or if they just need to be examined by a veterinarian and appear healthy. Do they need to carry a CVI or proof of a veterinary exam with them at all times during their visit to WA, or does the animal just need to be healthy?

Does the animal always have to be examined before being brought into WA, or can it be examined by a veterinarian within WA, such as a situation where a show has a required veterinary exam at the show before the animal is allowed in?

Also, you mentioned several diseases such as Salmonella, Histomonas meleagridis, Clostridium, Pasteurella, Bordatella, etc. that are commonly found asymptomatically in the systems of healthy animals of these species.

Are animals required to be tested for these things? How would a veterinarian ascertain whether an earthworm is carrying Histomonas meleagridis or a hamster is carrying salmonella, for example?

I have connections with rescues also, and frequently animals being rescued do have minor issues like mites, fleas, intestinal parasites, etc.

If it is not a reportable or controlled disease, and is not something that requires vaccines or testing, would such issues prevent an animal from being brought into the state?

Thank you very much,

-----------

Dr. Kohrs' reply:

February 21, 2012

Dear ------,

I will try to add more clarity to my last missive. To repeat: all animals entering the State of Washington are required to have a Certificate of Veterinary Inspection (CVI) also known as a health certificate. The exception to this rule is in regards to a dog, cat or ferret coming into this state, being transported in the owner’s vehicle for a brief visit at a private residence, do not need a CVI; however, they are required to have a certificate of rabies vaccination. If there are other animals at this private residence and there is mixing of the animals’, that is a matter between the person importing the animals and the person being visited.

If, on the other hand the animal(s) are being brought into the State of Washington for exhibition/sale at a public arena, the animal(s) are required to be examined by a licensed and accredited veterinarian and be issued a CVI which must accompany the animal(s) being imported. So, to answer your question of the animal being examined by a veterinarian and be issued a CVI before coming to an exhibition/show/sale, the answer is, yes. Bear in mind that the Washington State CVI is valid for only 30 days.

You commented about testing for the organisms mentioned; this would be up to the examining veterinarian. If the animal is showing signs of illness, no matter what the cause, the veterinarian will not issue a CVI. If then the animal’s owner wishes to find out the cause of the illness, tests may then be done to establish a cause. If the animal is asymptomatic and the owner wants to make sure there is no infectious organism being harbored, samples can be taken and tests run to determine if the animal is carrying Salmonella, Clostridium, Bordetella or any or any other known organism. When importing livestock, certain tests for diseases are required before entry into Washington, but not for the animals discussed here. As for rescue animals, we require they have a CVI and be vaccinated against rabies. If dogs are from a heartworm endemic area, they are required to be tested for heartworm and we do the best we can to oversee the importation of these rescue animals. However, we do not have the staff or the funding to cover all the rescue operations and rely on the integrity of the people doing the rescue.

In answer to your lasts [sic] question, I believe it has been taken care of in the body of this letter.

Sincerely,

Paul H. Kohrs, DVM

Again, these letters are being published with both original authors' permission.

A Veterinarian's Perspective on Health Certificate Laws

 (Posted with permission from Dr. Hreiz)

Dear ________,

Eric forwarded me your e-mail regarding concern over the requirement of a health certificate for rabbits crossing into the state.  As a veterinarian that routinely writes health certificates, I thought I would share my perspective with you over this requirement.

Believe it or not, this law is in place in almost every single US state requiring all companion animals and a myriad of exotic species to have a health certificate when crossing state lines.  Is this law strictly enforced?  Not at all.  I live in North Carolina and work right over the border in South Carolina.  There are many mornings I bring my retired racing Greyhound to the clinic for the day.  Do I prepare a health certificate for this 25 minute journey?  Absolutely not.  So from a legal standpoint I've broken this law at least 25 times.  The average rabbit breeder breaks this law every single weekend when driving to a show in another [state].  The typical family traveling home for Thanksgiving breaks this law multiple times as they cross over into each state on the way.  Simply put, there is virtually no way to enforce this law the way it is written.  The law is broken probably a million times per day.  

These laws are in place primarily for shipment of animals via air.  I routinely write health certificates for stray dogs in South Carolina that are being shipped via air to the northeast and placed into adoption homes.  So while I think the law looks alarming upon first inspection, it is important to realize the the enforcement of this law is not done.  Most US states do not have an inspection station when you're crossing state lines.  The only caveat to this would be a toll booth I guess - but even there a toll worker is clearly not interested if your beloved dog is in the back seat with the kids.

I hope this helps!

Sincerely,

Jay Hreiz
Chair, ARBA Rabbit & Cavy Health Committee

Updated: WA Health Certificates for Rabbits and Other Animals

Apparently the Show Rabbit Protection society is researching entry requirements for rabbits in various states. Here is their report on WA.

An excerpt:

There is at this time, no exemption in place for rabbits traveling into Washington that has been obtained by any agency or group including the ARBA.

We spoke with the staff in Dr. Paul Kohr's office, the Wa. Assistant State Veterinarian concerning traveling into Washington with show or sale rabbits.

At this time, all rabbits entering Washington regardless of quantity are required to have a veterinary health certificate from their out of state veterinarian before entering Washington for show or sale stating the rabbit is healthy and free of communicable disease and meets all of Washington's health standards.

I would recommend that you read the entire post.

The way WA law is written, technically any animal down to the level of an earthworm is required to have a health certificate, unless it is specifically exempted.

WAC 16-54-030 "(1)(a) A certificate of veterinary inspection must accompany all animals entering Washington state, except where specifically exempted in this chapter. Certificates of veterinary inspection expire thirty days from the date of issuance."

RCW 16.36.005(1) "Animal" means all members of the animal kingdom except humans, fish, and insects. However, "animal" does not mean noncaptive wildlife as defined in RCW 77.08.010, except as used in RCW 16.36.050(1) and 16.36.080 (1), (2), (3), and (5).

The exemptions can be found in the WAC section on animal importation.

It is important to be informed.

Addendum to post January 7, 2012:

It has come to our attention that some were misinterpreting our previous post as saying that people are not required to have health certificates for small animals coming from one town to another across state lines. So we have revised that paragraph to be more clear, as follows:

"Of course they aren't sending out staff to stop every car and see if you are smuggling a mouse across state lines, and 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."

Note that each individual animal is apparently considered a separate violation even if they are all traveling together. Each day it occurs is also considered a separate violation.

The bottom line is, the law clearly states that *all* animals not otherwise exempted need to have a health certificate when entering Washington. Communications from the state department have verified that this does include brief visits for shows.

According to the SRPS research, you are not required to have a health certificate when re-entering Washington with an animal that originated in Washington and is returning to the state within 30 days of when it left. Health certificates are only required for animals from out of state, not for animals being transported in Washington that originated in Washington.

Here are some of the relevant laws. Please click through each link to read the rest of the law--we are only posting excerpts on the blog for most of them.

RCW 16.36.050

(1) It is unlawful for a person to bring an animal into Washington state without first securing a certificate of veterinary inspection, reviewed by the state veterinarian of the state of origin, verifying that the animal meets the Washington state animal health requirements. This subsection does not apply to:

(a) Those animals that qualify for an exemption in RCW 16.36.140; or

(b) Other animals exempted by the director by rule.

RCW 16.36.110: Violations, gross misdemeanor

(1) Any person who violates any provision of this chapter or the rules adopted under this chapter shall be guilty of a gross misdemeanor. Each day upon which a violation occurs constitutes a separate violation.

RCW 16.36.113
Violations of chapter or rules — Civil penalty — Moneys collected — Time and mileage fee.

(1) Any person in violation of this chapter or its rules may be subject to a civil penalty in an amount of not more than one thousand dollars for each violation. Each violation is a separate and distinct offense. Every person who, through an act of commission or omission, procures, aids, or abets in the violation is in violation of this chapter or its rules and may be subject to the civil penalty provided in this section. Moneys collected under this section must be deposited in the state general fund.

(2) The department may charge a time and mileage fee for the cost of an investigation including inspecting animals and related records during an investigation of a proven violation of this chapter. The fee may be up to eighty-five dollars per hour and the current mileage rate set by the office of financial management. The director may increase the hourly fee by rule as necessary to cover costs of investigations. All fees collected pursuant to this subsection shall be deposited in an account in the agricultural local fund and used to carry out the purposes of this chapter.

[2011 c 204 § 11; 2007 c 71 § 4.]

The law on checkpoints and stopping vehicles for inspection:

RCW 16.36.045
Transporting of animals — Requirements — Vehicle inspection — Authorization by director or appointed officers.

The director may establish points of inspection for vehicles transporting animals on the public roads of this state to determine if the animals being transported are accompanied by valid health certificates, permits, or other documents as required by this chapter or its rules. Vehicles transporting animals on the public roads of this state are subject to inspection and must stop at any posted inspection point established by the director, with emphasis on livestock being brought in from outside the state. The director or appointed officers are authorized to stop a vehicle transporting animals upon the public roads of this state at a place other than an inspection point if there is reasonable cause to believe the animals are being transported in violation of this chapter or its rules.

[2007 c 71 § 1.]

This law addresses animals being transported without required documentation even within the state (i.e. not just while crossing the border). Our understanding is that this only applies to animals that were required to have a health certificate (CVI) in the first place (i.e. animals from outside WA). It does not apply to transporting an animal *from* Washington within the state, since a CVI is not required for them.

RCW 16.36.116 states,

"(1) Any person found transporting animals on the public roads of this state that are not accompanied by valid health certificates, permits, or other documents as required by this chapter or its rules has committed a class 1 civil infraction."

There is a fee schedule for fines here: WAC 16-92-020: Penalty schedule for notices of infraction. It's currently $100 per violation for the first offense.


The law also gives them the right to search your home or other property if they have reason to believe you have animals that were brought in illegally:

RCW 16.36.060
Tests, examinations, inspections, samples, examine and copy records — Entry onto property — Unlawful conduct — Seizure of property — Search warrant.

(1) The director has the authority to enter a property at any reasonable time to:

(b) Determine, when there is reasonable cause to investigate, whether animals on the property have been imported into Washington state in violation of requirements of this chapter, and to conduct tests, examinations, and inspections, take samples, and examine and copy records during such investigations.

(3) If the director is denied access to a property or animals for purposes of this chapter, or a person fails to comply with an order of the director, the director may apply to a court of competent jurisdiction for a search warrant. To show that access is denied, the director shall file with the court an affidavit or declaration containing a description of all attempts to notify and locate the owner or owner's agent and secure consent. The court may issue a search warrant authorizing access to any animal or property at reasonable times to conduct investigations, tests, inspections, or examinations of any animal or property, or to take samples, and examine and copy records, and may authorize seizure or destruction of property.

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 ++.)

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.