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The Animal Welfare Act
In 1970 the Animal Welfare Act (AWA) was enacted and authorized the Secretary of Agriculture to regulate warm-blooded animals when used in research, exhibition or in the wholesale pet trade. (Note: USDA use of the word “exhibition” implies animals put on display for profit such as in zoos and circuses and does not apply to agricultural fairs or breed shows). Since that time a number of other amendments have taken place that have modified the AWA. Currently, under the AWA, certain sales of rabbits are regulated and require a license from the USDA. These include wholesale rabbit sales to pet stores and pet dealers and direct sales to research facilities and exhibitors such as zoos in excess of $500 per year. Direct sales of rabbits as pets and for meat or fur are exempt from licensure. On May 16th, 2012 the USDA publically presented a proposed rule change that would further amend the AWA. This rule change would require all sales of warm-blooded animals as pets be conducted at the seller’s residence or place of business so the buyer could observe and inspect the animal at the time of purchase or prior to purchase.
How will this effect rabbit breeders?
If you sell any of your culls as pets you will have to allow the buyer to see the rabbit prior to purchase at your home or place of business or you will be required to be licensed by the USDA. If this amendment is put into effect as proposed even one sale of a rabbit away from your home or place of business could leave you open to prosecution by the USDA. So you say that you do not sell rabbits as pets and all your culls are sold to other breeders, 4-H participants or are used for meat or fur? Well sales for meat and fur will still be exempt, but in June 2002 the USDA published a document titled “USDA Rabbit Industry Profile”. In this document they stated the sale of breeding and/or show stock by hobby rabbit breeders is exempt from licensure up to $500 per calendar year and total gross sales exceeding $500 per year require the breeder to be licensed by the USDA. Recently various rabbit breeders have called the USDA and received contradictory information regarding the $500 limit on sales of breeding/show stock without a license.
What can the average rabbit breeder do about this proposed rule change?
The USDA is taking comments from the general public and stakeholders that will be affected by this rule change until July 16th, 2012. They have asked that rabbit breeders present our questions and concerns to them in writing or on the federal website portal. In my own personal conversation with the USDA veterinarian, Dr. Rushin, it was apparent they are uninformed about how rabbit breeders differ in their husbandry, sales, breeding and production compared to cat and dog breeders. Although the proposal for this rule change states the reason for the rule change is to protect consumers buying primarily dogs sight unseen over the internet, they have included any warm blooded domestic animal sold as a pet in this proposal. We as rabbit breeders need to educate them on the following facts about our hobby:
1) Rabbit breeders do not breed and show rabbits to make money. We do so to improve our breed and to maintain quality herds. Most of us are fortunate if our sale proceeds even begin to cover our feed bill let alone the rest of our expenses.
2) From ARBA membership numbers and statistics on how many youth participate in 4-H and FFA rabbit projects, we know that one-third to one-half of rabbit breeders in the US are minors under the age of 18. Minors cannot legally become licensed. Requiring pet sales at the residence of a minor is a safety concern when the same sale could be conducted with the animal present at a rabbit show, fair or public place. The safety of minors should be of a greater concern that consumer protection when purchasing a pet.
3) Unlike dogs and cats, rabbits are multi-purpose animals used for a variety of purposes. Limiting sales of show/breeding rabbits to $500 per year will damage the hobby as a whole and reduce the numbers of purebred rabbits available for meat and fur as well as for FFA and 4-H participants.
4) The majority of rabbit sales are conducted at rabbit shows whether they be pet, breed or show stock sales because rabbit breeders tend to live long distances from each other. Our numbers are much smaller that dog breeders, and in the case of rare rabbit breeds, may even be states away or in different regions of the US.
5) First and foremost, rabbits are multi-purpose agricultural animals and rabbit breeders should be afforded the same protection under the law as producers of other livestock animals. Pet sales are a minor offshoot of the hobby and not the primary aim of the breeding of rabbits.
6) We rabbit breeders need to be clear in our comments to the USDA that we want rabbits to be exempt from such legislation and that we are opposed to this rule change of the AWA.
As well as making comments to the USDA it would be helpful if you can also send a copy of your concerns, questions and comments to your US Congressional Representative and the U.S. Secretary of Agriculture, Tom Vilsack. Below is the contact information for all the above-mentioned entities:
Federal Comment Portal:
http://www.regulations.gov/#!documentDetail;D=APHIS-2011-0003-0001
Or you can mail comments to:
Docket No. APHIS-2011-0003
Regulatory Analysis and Development, PPD, APHIS
Station 3A-03.8
4700 River Road, Unit 118
Riverdale, MD 20737-1238
Tom Vilsack
U.S. Secretary of Agriculture
1400 Independence Ave., S.W.
Washington, DC 20250
http://www.regulations.gov/?_escaped_fragment_=documentDetail;D=APHIS-2011-0003-0001
www.regulations.gov
In 1970 the Animal Welfare Act (AWA) was enacted and authorized the Secretary of Agriculture to regulate warm-blooded animals when used in research, exhibition or in the wholesale pet trade. (Note: USDA use of the word “exhibition” implies animals put on display for profit such as in zoos and circuses and does not apply to agricultural fairs or breed shows). Since that time a number of other amendments have taken place that have modified the AWA. Currently, under the AWA, certain sales of rabbits are regulated and require a license from the USDA. These include wholesale rabbit sales to pet stores and pet dealers and direct sales to research facilities and exhibitors such as zoos in excess of $500 per year. Direct sales of rabbits as pets and for meat or fur are exempt from licensure. On May 16th, 2012 the USDA publically presented a proposed rule change that would further amend the AWA. This rule change would require all sales of warm-blooded animals as pets be conducted at the seller’s residence or place of business so the buyer could observe and inspect the animal at the time of purchase or prior to purchase.
How will this effect rabbit breeders?
If you sell any of your culls as pets you will have to allow the buyer to see the rabbit prior to purchase at your home or place of business or you will be required to be licensed by the USDA. If this amendment is put into effect as proposed even one sale of a rabbit away from your home or place of business could leave you open to prosecution by the USDA. So you say that you do not sell rabbits as pets and all your culls are sold to other breeders, 4-H participants or are used for meat or fur? Well sales for meat and fur will still be exempt, but in June 2002 the USDA published a document titled “USDA Rabbit Industry Profile”. In this document they stated the sale of breeding and/or show stock by hobby rabbit breeders is exempt from licensure up to $500 per calendar year and total gross sales exceeding $500 per year require the breeder to be licensed by the USDA. Recently various rabbit breeders have called the USDA and received contradictory information regarding the $500 limit on sales of breeding/show stock without a license.
What can the average rabbit breeder do about this proposed rule change?
The USDA is taking comments from the general public and stakeholders that will be affected by this rule change until July 16th, 2012. They have asked that rabbit breeders present our questions and concerns to them in writing or on the federal website portal. In my own personal conversation with the USDA veterinarian, Dr. Rushin, it was apparent they are uninformed about how rabbit breeders differ in their husbandry, sales, breeding and production compared to cat and dog breeders. Although the proposal for this rule change states the reason for the rule change is to protect consumers buying primarily dogs sight unseen over the internet, they have included any warm blooded domestic animal sold as a pet in this proposal. We as rabbit breeders need to educate them on the following facts about our hobby:
1) Rabbit breeders do not breed and show rabbits to make money. We do so to improve our breed and to maintain quality herds. Most of us are fortunate if our sale proceeds even begin to cover our feed bill let alone the rest of our expenses.
2) From ARBA membership numbers and statistics on how many youth participate in 4-H and FFA rabbit projects, we know that one-third to one-half of rabbit breeders in the US are minors under the age of 18. Minors cannot legally become licensed. Requiring pet sales at the residence of a minor is a safety concern when the same sale could be conducted with the animal present at a rabbit show, fair or public place. The safety of minors should be of a greater concern that consumer protection when purchasing a pet.
3) Unlike dogs and cats, rabbits are multi-purpose animals used for a variety of purposes. Limiting sales of show/breeding rabbits to $500 per year will damage the hobby as a whole and reduce the numbers of purebred rabbits available for meat and fur as well as for FFA and 4-H participants.
4) The majority of rabbit sales are conducted at rabbit shows whether they be pet, breed or show stock sales because rabbit breeders tend to live long distances from each other. Our numbers are much smaller that dog breeders, and in the case of rare rabbit breeds, may even be states away or in different regions of the US.
5) First and foremost, rabbits are multi-purpose agricultural animals and rabbit breeders should be afforded the same protection under the law as producers of other livestock animals. Pet sales are a minor offshoot of the hobby and not the primary aim of the breeding of rabbits.
6) We rabbit breeders need to be clear in our comments to the USDA that we want rabbits to be exempt from such legislation and that we are opposed to this rule change of the AWA.
As well as making comments to the USDA it would be helpful if you can also send a copy of your concerns, questions and comments to your US Congressional Representative and the U.S. Secretary of Agriculture, Tom Vilsack. Below is the contact information for all the above-mentioned entities:
Federal Comment Portal:
http://www.regulations.gov/#!documentDetail;D=APHIS-2011-0003-0001
Or you can mail comments to:
Docket No. APHIS-2011-0003
Regulatory Analysis and Development, PPD, APHIS
Station 3A-03.8
4700 River Road, Unit 118
Riverdale, MD 20737-1238
Tom Vilsack
U.S. Secretary of Agriculture
1400 Independence Ave., S.W.
Washington, DC 20250
http://www.regulations.gov/?_escaped_fragment_=documentDetail;D=APHIS-2011-0003-0001
www.regulations.gov
