New USDA rules would truly affect our breed.
Posted: Wed Oct 12, 2011 11:05 pm
To all:
I am posting this on our list, with the request that you all read it and if at all possible, also take action in the form of a protest to the USDA.
In a nutshell, they are proposing the ban of imported pups, younger than 6 months old. If breeders can no longer import pups, and are limited to adult dog imports only, that greatly and negatively affect the already limited genepool. Please take some time to at least forward this to all the dog groups that you are a member of, and urge them too to take action. The deadline is in two weeks. Spread the word!!!
Judith
http://www.aphis.usda.gov/newsroom/2011 ... d_dogs.pdf
From: Jeanne Lorang
IMPORTANT - if you have ever
imported/want to import a puppy, read this! And take action!!!
Please forward!
USDA APHIS Animal Care (the people I work for) are proposing a new
rule regarding the import of puppies. It is supported by AKC, and
by NAIA. Heck, I support what it is trying to do, but I have a
huge issue with it as well. The new rule (you can reach it through
http://www.aphis.usda.gov/newsroom/2011 ... dogs.shtml)
requires an import permit for dogs imported for resale or
research, and that permit will not be granted for any dog under 6
months. It is designed to stop the flow of underage, unvaccinated
puppies that are being brought in and sold on the internet. I've
seen shipments of these, and the dead, sick puppies in them.
Great, let's stop it! Absolutely!
BUT< BUT< BUT - the new rule does NOT offer what is called a
"de minimus" exception. If you want to import a single puppy, or
even 2, there is no assumption that they are not for resale, or
any mechanism for you to prove or demonstrate that they are not
for resale. In other words, they can (AND WILL) use this rule to
block the import of any puppy under 6 months of age, by assuming
it is for resale. How many breeders abroad are going to hold a
puppy for you until it is 6 months old? How many approved shippers
abroad, who actually have to put the puppy on the plane, will
refuse to handle 8 week old puppies? How much extra will it cost
to ship a 6 month old pup, IF you can get a breeder to hold it? I
would hate to get a permit, would if I had to, BUT the age limit
is a killer. And if a dog is blocked, the importer can be forced
to pay for quarantine, and the cost of adopting the animal out!
Lose the pup, and have to pay for it! See it get spayed/neutered
at 4 - 6 months and sent to a new home, all at your expense.
All it will take under this rule is for one agent at one airport
to assume the pup is for resale, no matter what you say, and that
pup will be blocked from entering the country (if it is even
accepted by the airline). This rule HAS to be amended to include a
hard and fast mechanism for ensuring that puppies can be proven
not to be for resale, or we will no longer be able to afford to
import pups. I know how the system works, I'm part of it - if this
rule does not include such a mechanism, we are so screwed.
I had a chance to comment on this rule months ago, intra agency. I
explained how this would impact the pure bred dog breeders.
Obviously, I was ignored. But, the way rulemaking works, they
cannot ignore public comments. Every comment has to be read, and
every issue addressed. I mean EVERY comment has to be read, they
detail people in to do this, if enough comments are received. If
enough people protest the lack of a mechanism to ensure breeders,
and even pet owners who want to buy abroad, can bring in pups
under 6 months, they have to modify the rule, or give a damn good
reason why not. So please, please, take the time to comment.
My own suggestion?
1) Point out that anyone importing just 1 or 2 pups per year is
very unlikely to be doing it for resale. Demand that a "de
minimus" threshold be included, so those bring in only 1 or 2 or 3
pups per year do not need an import permit (or can be granted one
for an 8 week old pup), and the pups are assumed not to be for
resale, and that the exemption be included in the rule.
2) Point out that most reputable breeders in Europe cannot
afford/will not be bothered to hold pups until they are 6 months
old, and most hobby breeders cannot afford the cost of such
holding, and shipping.
3) Point out that forcing a puppy to wait until 6 months old to be
integrated into a new home is more detrimental to that pup than
bringing it in at 8 - 12 weeks old.
4) Point out that the genetics of dog breeding, especially in some
breeds, means the free flow of blood lines.
5) For good measure, point out that they are requiring vaccines
that are not core vaccines by the AVMA, such as Lepto. Give Lepto
to a pup??
Point out whatever you want, but please, please get this rule
amended! If several hundred comments are received, they cannot be
ignored. Comments can be submitted by email, at
http://www.regulations.gov/#!documentDe ... -2009-0053.
Comments have to be in by 10-31, but don't delay, and get your
friends to comment. Volume counts, seriously. PETA wins on issues
such as this by getting in thousands of identical comments, but
thoughtful comments are given more weight.
PLEASE FORWARD!! The farther the better.
Jeanne Lorang
Lebec Briards
http://www.Briard.com
I am posting this on our list, with the request that you all read it and if at all possible, also take action in the form of a protest to the USDA.
In a nutshell, they are proposing the ban of imported pups, younger than 6 months old. If breeders can no longer import pups, and are limited to adult dog imports only, that greatly and negatively affect the already limited genepool. Please take some time to at least forward this to all the dog groups that you are a member of, and urge them too to take action. The deadline is in two weeks. Spread the word!!!
Judith
http://www.aphis.usda.gov/newsroom/2011 ... d_dogs.pdf
From: Jeanne Lorang
IMPORTANT - if you have ever
imported/want to import a puppy, read this! And take action!!!
Please forward!
USDA APHIS Animal Care (the people I work for) are proposing a new
rule regarding the import of puppies. It is supported by AKC, and
by NAIA. Heck, I support what it is trying to do, but I have a
huge issue with it as well. The new rule (you can reach it through
http://www.aphis.usda.gov/newsroom/2011 ... dogs.shtml)
requires an import permit for dogs imported for resale or
research, and that permit will not be granted for any dog under 6
months. It is designed to stop the flow of underage, unvaccinated
puppies that are being brought in and sold on the internet. I've
seen shipments of these, and the dead, sick puppies in them.
Great, let's stop it! Absolutely!
BUT< BUT< BUT - the new rule does NOT offer what is called a
"de minimus" exception. If you want to import a single puppy, or
even 2, there is no assumption that they are not for resale, or
any mechanism for you to prove or demonstrate that they are not
for resale. In other words, they can (AND WILL) use this rule to
block the import of any puppy under 6 months of age, by assuming
it is for resale. How many breeders abroad are going to hold a
puppy for you until it is 6 months old? How many approved shippers
abroad, who actually have to put the puppy on the plane, will
refuse to handle 8 week old puppies? How much extra will it cost
to ship a 6 month old pup, IF you can get a breeder to hold it? I
would hate to get a permit, would if I had to, BUT the age limit
is a killer. And if a dog is blocked, the importer can be forced
to pay for quarantine, and the cost of adopting the animal out!
Lose the pup, and have to pay for it! See it get spayed/neutered
at 4 - 6 months and sent to a new home, all at your expense.
All it will take under this rule is for one agent at one airport
to assume the pup is for resale, no matter what you say, and that
pup will be blocked from entering the country (if it is even
accepted by the airline). This rule HAS to be amended to include a
hard and fast mechanism for ensuring that puppies can be proven
not to be for resale, or we will no longer be able to afford to
import pups. I know how the system works, I'm part of it - if this
rule does not include such a mechanism, we are so screwed.
I had a chance to comment on this rule months ago, intra agency. I
explained how this would impact the pure bred dog breeders.
Obviously, I was ignored. But, the way rulemaking works, they
cannot ignore public comments. Every comment has to be read, and
every issue addressed. I mean EVERY comment has to be read, they
detail people in to do this, if enough comments are received. If
enough people protest the lack of a mechanism to ensure breeders,
and even pet owners who want to buy abroad, can bring in pups
under 6 months, they have to modify the rule, or give a damn good
reason why not. So please, please, take the time to comment.
My own suggestion?
1) Point out that anyone importing just 1 or 2 pups per year is
very unlikely to be doing it for resale. Demand that a "de
minimus" threshold be included, so those bring in only 1 or 2 or 3
pups per year do not need an import permit (or can be granted one
for an 8 week old pup), and the pups are assumed not to be for
resale, and that the exemption be included in the rule.
2) Point out that most reputable breeders in Europe cannot
afford/will not be bothered to hold pups until they are 6 months
old, and most hobby breeders cannot afford the cost of such
holding, and shipping.
3) Point out that forcing a puppy to wait until 6 months old to be
integrated into a new home is more detrimental to that pup than
bringing it in at 8 - 12 weeks old.
4) Point out that the genetics of dog breeding, especially in some
breeds, means the free flow of blood lines.
5) For good measure, point out that they are requiring vaccines
that are not core vaccines by the AVMA, such as Lepto. Give Lepto
to a pup??
Point out whatever you want, but please, please get this rule
amended! If several hundred comments are received, they cannot be
ignored. Comments can be submitted by email, at
http://www.regulations.gov/#!documentDe ... -2009-0053.
Comments have to be in by 10-31, but don't delay, and get your
friends to comment. Volume counts, seriously. PETA wins on issues
such as this by getting in thousands of identical comments, but
thoughtful comments are given more weight.
PLEASE FORWARD!! The farther the better.
Jeanne Lorang
Lebec Briards
http://www.Briard.com
including a ride to the German airport of Weeze 
and crosspost to all dog lists.