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Tuesday, May 14, 2019
https://www.akc.org/legislative-alerts/proposed-changes-usda-pet-breeder-dealer-licensing-requirements-one-week-left-comment/
The USDA's Animal and Plant Health Inspection Service (USDA APHIS), which is
charged with enforcement of the federal Animal Welfare Act (AWA), continues to
accept comments from the public on proposed updates to the AWA's licensing
requirements. Comments will be accepted through Tuesday, May 21, 2019. The
American Kennel Club (AKC) generally supports the proposed changes and
encourages all interested parties to submit thoughtful, experience-based
written comments online before the end of next week's comment period.
Current USDA regulations require that pet breeders who maintain more than 4
"breeding females" (dogs, cats or other small mammals) and sells one sight
unseen may be subject to licensing to USDA licensing. For more information on
licensing requirements, view AKC's Does the New USDA Rule Affect Me? or visit
https://www.aphis.usda.gov/aphis/ourfocus/animalwelfare/awa/ct_awa_program_information.
USDA APHIS is seeking public comments on a proposal to:
• Amend its licensing requirements to eliminate automatic renewals.
With this change, licensees would have to demonstrate compliance, via a
facility inspection, with the AWA and show that the animals in their possession
are adequately cared for in order to obtain a license.
• Provide temporary licensing procedures to avoid inadvertent lapses of
licensure by historically compliant licensees if a delay or backlog in USDA
inspections occurs.
• Strengthen existing regulations to prevent individuals and businesses
whose licenses were suspended or revoked from working for regulated entities.
• Reduce regulatory burdens on fully compliant licensees. To accomplish
this, APHIS is taking steps to streamline the licensing process by reducing
licensing fees-a set $120 fee for a three-year license-and simplifying the
payment and collection process.
• Require any dealer, exhibitor or research facility with dogs to
maintain a written program for veterinary care and medical records and to make
those records available to USDA upon request. [Please note that the term
"exhibitor" refers to carnivals, circuses, animal acts, zoos, and educational
exhibits. It specifically does not include purebred dog shows.) The written
veterinary care program would have to include regular visits by the attending
veterinarian to conduct a complete physical examination of each dog not less
than once a year, vaccinations for contagious and deadly diseases of dogs, and
preventative care and treatment for hair coats, nails, eyes, ears, skin, and
teeth.
The American Kennel Club supports the above changes.
The proposal also mandates that dogs in regulated facilities have continual
access to potable water unless restricted by an attending veterinarian.
However, as stated by USDA, a lack of continual access to water is generally
not a risk to healthy dogs. (Proposal, 84 FR 10728,
https://www.federalregister.gov/d/2019-05422/page-10728) Because regulated
facilities vary by type, size, and the number of animals they maintain,
standards that would allow licensees some flexibility in operations while still
providing appropriate care may be a better, more easily achieved alternative.
The AKC is also concerned that the proposed changes fail to provide a clear
definition of the term "breeding female" as used in AWA regulations.
Currently, the USDA appears to define "breeding female" as "capacity to breed"
and bases this assessment on a case-by-case visual inspection on the ground of
the animals involved, determining whether they are "of breeding age" and
whether there are health or other factors that would limit that. The AKC
believes that this is not a practical, efficient, or clear way to establish a
threshold for licensing and regulation, as it does not allow either APHIS or a
breeder to assess whether a breeder would be subject to licensing, regulation,
and inspection without first being inspected by APHIS, which could only be
undertaken after the license application process has been undertaken.
Unless a breeder is certain which animals will "qualify" as non-breeding
animals, a breeder has no way of knowing what their regulatory requirements
would be under this rule. Visual or arbitrary definitions of "breeding
females" are also problematic as many breeders "grow out" promising females to
at least 24 months of age before determining whether they will have a show
career or be worthy of breeding. Maintaining an intact female that physically
could be bred does not indicate the intention to breed.
WHAT YOU CAN DO:
Interested parties are encouraged to submit comments to USDA APHIS by going to
https://www.federalregister.gov/documents/2019/03/22/2019-05422/animal-welfare-amendments-to-licensing-provisions-and-to-requirements-for-dogs.
Click "Submit A Formal Comment" and submit your comment along with the
required information.
AKC Government Relations (AKC GR) will provide updates on the regulatory
process as the proposal proceeds. For more information on this or other
federal legislative or regulatory issues, contact AKC's Government Relations
Department at (919) 816-3720 or doglaw@xxxxxxx.
Stormy Hope
LLARTC
NAIATrust, Trustee
NAIATrust-CA on Facebook!
GSDCA Legislative Liaison to AKC
California Responsible Pet
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