A Sufficient Life
|Posted by Shannon on June 27, 2012 at 5:30 PM|
If you have not read the ACTUAL proposed changes to the
Animal Welfare Act which is administered by the USDA and APHIS,
here they are:
My three biggest concerns with the proposed changes to the
Animal Welfare Act administered by the USDA and APHIS are:
1) "Specifically, we would narrow the definition of retail pet store so that it
means a place of business or residence that each buyer physically enters in
order to personally observe the animals available for sale prior to purchase
and/or to take custody of the animals after purchase, and where only certain
animals are sold or offered for sale, at retail, for use as pets."
[Docket No. APHIS-2011-0003]
I don't know about you, but I don't want to have to let anyone and everyone onto
my property. During a teleconference held with the Show Rabbit Protection
Society, Dr. Gerald Rushin of the USDA/APHIS, one of the drafter's of the
proposed legislative changes, told SRPS members that
"We just want to make sure that people who are buying your animals, have the
opportunity to check out the condition of those animals, and if they don't, if htey
are being sold over the internet, then APHIS comes into play, by that rule and will
check out the conditions of the animals, before they are sold. So as long as those
people are having the opportunity to come in and view your pets, even if they are in
a seperate location, but they see your pet, you are good to go."
This seems to indicate that meeting the potential buyer offsite and allowing
them to see the animal before purchase also meets the "retail pet store"
definition, as long as there is face to face contact. This needs to be spelled
out in the proposed legislative changes.
2)" We are also proposing to 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 the licensing and inspection
requirements."[Docket No. APHIS-2011-0003]
There is no way a commercial rabbit breeder can break even with only 4 breeding
females. That may be enough for someone that is only breeding for their family's
use, but anyone that breeds to sell for any reason, will need more than 4
In the teleconference transcript, Mary Hammond of the SRPS ask this,
"I want to confirm, just a minute, let me find it, the three to four breeding female limit
does not apply to rabbits."
To which Dr. Rushin replied, "That does not apply to rabbits."
NOWHERE in the proposed legislative changes does it say rabbits are excluded.
This also needs to be spelled out clearly.
3)" A person may...be exempt from the licensing and inspection requirements...if
he or she sells only the offspring of those animals born and raised on his or
her premises, for pets or exhibition. This exemption would apply regardless of
whether those animals are sold at retail or wholesale." [Docket No. APHIS-2011-0003]
What if I want to later sell an animal that I purchased, after using it in my
program? It was not born here....am I not allowed then to sell it without having
my exemption taken away?
In the teleconference, this question was raised by Mary Hammond of the SRPS and
answered by Ms. Jones and Dr. Rushin of the USDA:
Hammond: Now since rabbits don't fall under the three to four breeding females,
are they also exempt from the requirement to only sell what is born and raised
on the property issue?
Jones: Which regulation are you citing?
Hammond: the individual only will sell that which is born and raised, for
example, let's go back to the heritage breeds. I purchase an a breeding buck for
the purpose of widening my gene pool, the goal is accomplished and I want to
resell him, am I now, because that buck was not born and raised on my property,
going to need a license to resell?
Jones: I don't have the passage in front of me, but the only place we discuss, as I recall, animals born
and raised on the property, is the proposed four female rule, so that would probably still fall
under that rule.
Hammond: So that does not apply to rabbits.
Rushin: Right. That is correct.
This would also seem to indicate that they don't mean this portion of the
proposed changes to apply to rabbits, which again, is not ANYWHERE in the
document and also needs to be spelled out clearly in the proposed legislative