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Author: Rob Usakowski
Many of us have heard some of the horror stories of puppy
mills.
News programs describe the unsanitary conditions, the uncontrolled
breeding and the poor condition of the animals.
Congress has responded by introducing a billed called the
Pet Animal Welfare Statue of 2005. This bill is an amendment
to the Animal Welfare Act. It's in the Senate as bill S1139
and in the House as HR2669. Currently this bill is in the
Senate Committee on Agriculture, Nutrition and Forestry's
Subcommittee on Research, Nutrition and General Legislation.
Its most recent hearing on this bill was held on November
8.
On the surface one would think that this bill is a good thing.
However, after taking a closer look clearly this bill is designed
to do more than regulate the poor conditions of puppy mills.
In fact this bill reaches breeders of all types including
hobby breeders. Rabbits are included in this legislation,
and if
you are a rabbit breeder you should take note of this bill.
Current Animal Welfare Act Regulations
Currently the sale of pets for anything other than food or
fiber is a regulated activity. The sale of pets directly to
owners is however exempted from those regulations. As a rabbit
breeder if you sell your rabbits as pets directly to a consumer
you are not under the current legislation and are therefore
not required to obtain a USDA license. This is called the
retail exemption.
There is some gray area regarding the sale of your stock to
a breeder or selling as a show animal. Under current legislation
it is likely that those sales would fall under the same rules
as a pet sale. Breeders that choose to sell directly to pet
stores do fall under the guidelines of current legislation
and are required to obtain a license from the USDA.
What Changes Does PAWs Make?
Under new legislation the retail exemption described above
is removed. The proposed licensing threshold for all species
except for dogs and cats is sales of $500. The limit for dog
and cat sales is 25 animals. This alone shows a huge disparity
in this bill. It is not uncommon to see pure bred dogs for
sale in news papers for $300 and up. Meaning a dog breeder
could have sales of $7500 just at $300 per animal, while rabbit
breeders would be limited to $500. Considering that good quality
show rabbits will often sell for over $100 that would limit
most breeders to just one or two litters.
The problem becomes the USDA regulations that accompany not
only obtaining, but in keeping the license. There are over
80 pages of regulations related to obtaining the USDA license.
An inspection is required for the license. Currently, the
USDA is understaffed, and complaints are often received concerning,
inconsistent application of the regulations by the various
inspectors.
Some of the regulations would make it virtually impossible
for the rabbit breeder to keep breeding. For example, under
USDA regulations someone over the age of 18 must be present
at your
facility for unannounced inspections between the hours of
7am - 7pm Monday thru Friday. Imagine having to pay a staff
to be present when you're not. Add that to the fact that rabbit
breeders rarely show a net profit and you can already see
a portion of the problems this legislation will cause for
rabbit breeders.
I think most of us have treated our rabbits for various ailments
without taking them to a veterinarian. We have either talked
to other local breeders, or visited rabbit forums and found
the answer for the problems our stock has had. I have yet
to have any complications from any treatment my rabbits have
received.
Can you imagine the cost of having to take those animals to
a vet, better yet imagine the cost of having the vet come
to your facility every time an animal is ill? Under USDA regulations
that is exactly what you would be required to do. You would
have to have a formal agreement with a veterinarian to come
to your facilities to not only treat but also monitor your
rabbits. I have taken rabbits to the vet as necessary, but
not with every problem.
A USDA license would make your rabbitry a retail establishment.
This means that you may be required to get zoning approval
by your local government. Depending on where you live this
might
not even be possible. Certainly, if you live in most residential
communities, you would be forced out of breeding. Some breeders
may try to go "underground", but the USDA plans
to require all
animals under its legislation to be required to be in its
National Animal Identification System by 2009. It will track
every animal for birth to death making it virtually impossible
to sell even if underground.
As you can see already this legislation would cause an abundance
of paper work. We keep very good records of everything that
happens in our rabbitry, however the additional requirements
for
USDA licensing would require us to either devote more time
to what is just a hobby, or hire someone to do the extra work.
Again, how many of rabbit breeders actually make money?
Of course the USDA has certain facility requirements as well.
Your rabbitry would have to be waterproof, which would virtually
eliminate barns with dirt floors, barns with unfinished or
wood
walls, and housing of rabbits outside. Stainless steel sinks
and grooming tables may become necessary. Again this may be
cost prohibitive for many breeders. USDA requirements state
that your
facilities must be such that they can be hosed out and sanitized.
Transportation of regulated animals is also effected. Your
transportation must be commercially inspected and you must
carry commercial insurance on that vehicle. So much for traveling
to the rabbit shows!
Who Supports Paws?
Who is the one of the biggest supporter of this legislation?
PETA (People for the Ethical Treatment of Animals). Here are
a few of PETA's thoughts on rabbits. Rabbits should have food
in front of them 24 hours a day 7 days a week. Maybe they
don't
understand that having an overweight rabbit is unhealthy for
the rabbit. Nest boxes should remain in the rabbit cage until
the kits are 4 weeks old. Maybe they haven't had to deal with
the eye infections that can occur as a result of this practice.
Wire floors are cruel to rabbits. Maybe they haven't seen
how quickly unsanitary a cage can become when it has a solid
floor.
Don't be fooled by PETA's name, there intent is to abolish
pet ownership all together. Here's a quote from Ingrid Netwkirk,
director of PETA, "Pet ownership is an absolutely abysmal
situation brought about by human manipulation." Here's
another quote, "You don't have to own squirrels and starlings
to get enjoyment from them ... One day, we would like an end
to pet shops and the breeding of animals."
What Can You Do?
I know many of you may be like me. I vote in nearly every
election, I often read about things that are happening politically,
but I rarely take action outside of voting. If you are a rabbit
breeder, you need to step out of that comfort zone, or that
hobby or business that you run may be greatly impacted
to the point that you can now longer breed rabbits.
As a minimum please email the members of the senate subcommittee.
You can go to this site and near the bottom of the page is
a link SAOVA that
will generate an email to all of the committee members. Please
be sure to include a polite message describing your opposition
to the bill. Be sure to include you name and mailing address
in the email. Or you may call the Agriculture Committee at
202-224-2035 or the AG Subcommittee at 202-224-5270. You can
also visit Vote Smart to
contact your local representatives. It is important that you
take action quickly as the subcommittee has already had its
hearing on the matter. Because of the misconception that this
bill is only to eliminate puppy mills, should this legislation
get out of committee there is a good chance that it will pass
in congress. Working together we can keep our hobby and passion
for rabbits a viable opportunity for all.
About the author: Rob Usakowski is owner of Three Little
Ladies Rabbitry which is run by his wife Cathie and their
three daughters. Visit their site Three
Little Ladies Holland Lops for lots of rabbit raising
information for both pet owners and breeders alike. |
