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Originally posted on July 9, 2018 at NAIA Official Blog, reposted with permission.

More troubling news from the wild world of rescue import has been picked up by the Worms & Germs blog : a rescue dog with a known history of chronic health issues is imported into a private U.S. shelter from Thailand and tests positive for Melioidosis, a nasty zoonotic bacterial disease. This discovery leads to several potentially exposed people receiving blood tests (one showed signs of exposure, but none got sick), and ultimately the euthanasia of the dog.

Melioidosis is bad news

 

The plea for common sense from Worms & Germs author, Scott Weese (Ontario Veterinary College – University of Guelph), could have been written by us:

 

Logical importation practices are needed. How much time and expense went into shipping a paralysed dog transcontinentally from one shelter to another, when it was ultimately euthanized in the end anyway? I realize everything is done with good intentions, but thank about what could have been done for local homeless animals with the time, effort and expenses that were incurred here.

 

Dr. Weese generously labels the shelters and importers as well intentioned. But honestly, there must be a point where, when operations are carried out with such casual disregard for the health of shipped and local dogs (and adopters), where intentions can not be labeled as “good” — or at the end result is so damaging as to make intentions irrelevant.

 

Rescue importation, fueled by a lack of adoptable local dogs in many parts of the U.S. and the power of social media, has grown by leaps and bounds over the last two decades while U.S. dog import laws have not been updated since 1956. As a result, we are seeing dogs arrive here with everything from canine brucellosis, rabies, and the canine flu, to parasites and other vector-borne diseases. These are very serious issues, which is why NAIA has been working to modernize dog import laws for the last several years.

For more information, contact Patti Strand, NAIA President, at naia@naiaonline.org.

 

 

An interesting study about ordinances governing backyard poultry ownership in Colorado was recently published, titled “A Method for Guarding Animal Welfare and Public Health: Tracking the Rise of Backyard Poultry Ordinances” (the “Report”).

The Report “tracks the development of municipal ordinances, with attention to provisions for animal health and welfare and significant concerns for public health.”

Public and animal health officials, as well as large commercial poultry operations, have been concerned about the spread of infectious, contagious diseases, such as avian influenza virus from small backyard flocks where owners are unaware of and not familiar with the typical biosecurity measures that are generally recommended in animal agriculture.

USDA has published a number of guidance documents for people interested in raising poultry for their personal consumption of eggs.

In “Biosecurity for Birds,” USDA explains:

Raising backyard poultry is a growing trend across the United States. It is very important for all backyard poultry owners to know the signs of two deadly poultry diseases, as well as the basic ‘biosecurity’ steps you can take to protect your birds. APHIS runs the Biosecurity for Birds campaign to help raise awareness among backyard, hobby and pet bird owners.

On the other hand, animal rights activists often blame commercial agriculture for the spread of avian influenza.  See, e.g., An HSUS Report: Human Health Implications of Intensive Poultry Production and Avian Influenza, and Avian Influenza Just One Marker of Sickness in Industrial Agriculture .

The fact is that avian influenza is most often spread from wildlife to privately owned domestic flocks, regardless of the size of the flock.  Therefore, for animal and public health concerns, statutes and regulations̶̶-federal, state, or local-should provide for the health and welfare of laying hens as well as ensuring quality standards for eggs.

Federal and state laws govern standards of egg quality relating to the prevention of contamination with Salmonella.  As the Report discusses:

The federal regulations include requirements related to egg handling and storage prior to point of purchase by consumers, as well as testing for Salmonella on farms that have more than 3000 hens and implementation of biosecurity programs on those farms to control egg safety risks. For poultry meat safety, USDA inspects live birds and carcasses at federally inspected slaughter plants (i.e., plants that process meat for export or interstate commerce) to ensure that they are free of disease, and also evaluates conditions at those plants to ensure that they are sanitary and following ‘good commercial practices.’

However, as the Report states, local ordinances that permit ownership of backyard poultry usually do not include provisions related to either the health or safety of the hens.

[B]ackyard birds may pose significant risks to the general public. The outbreak of highly pathogenic avian influenza (HPAI, H5N1) in Egypt offers a shocking example. The majority (107/112) of Egypt’s clinically confirmed HPAI cases of human infection from 2006 to 2009 are linked to close contact with diseased backyard birds resulting in 36 deaths and human-to-human spread. In addition, the 2002 California outbreak of Exotic Newcastle Disease (END) originated in backyard flocks. The outbreak spread into commercial operations and resulted in depopulation of over 3 million birds, costing taxpayers $161 million. (citations omitted).

The Report, analyzing backyard poultry ordinances in Colorado, found, in part:

  1. The most common guidelines for poultry ordinances pertain to housing design and placement, the sex of birds, and total number of birds allowed, including specific space requirements for birds, in come cases.
  2. Ordinances commonly required housing to be predator resistant, easily cleaned, and maintained regularly to prevent the development of pests, rodents, or odors that would cause nuisances.
  3. In urban locations, the number of birds permitted was often limited to between 4 and 6 birds per lot.
  4. Ventilation requirements were often not included in ordinances.
  5. Roosters were commonly prohibited.

Notably, the Report stated that “[r]egulations pertaining directly to animal health and welfare were rare.”

The Report concluded that ordinances should include these provisions.

[O]ur study indicates that there are fewer guidelines for the health and welfare of backyard poultry than their commercial counterparts. Regulation is important in disease prevention. Fragmented oversight of animal welfare and health creates policy blind spots critical to shared human and animal health.

I concur.

A set of bills introduced in the New Jersey legislature would dilute funds from the decades-long spay neuter program overseen by the Department of Health, to the detriment of pets and their owners.

New Jersey bill S883 and sister bill A 2197 would authorize the New Jersey Motor Vehicle Commission “to issue special Humane State license plates . . . [and] [a]fter the deduction of the cost of designing, producing, issuing, renewing, and publicizing the plates and of any computer programming changes that are necessary to implement the license plate program, in an amount not to exceed $150,000, the additional fees will be deposited into a special non-lapsing fund known as the ‘Humane State License Plate Fund”’ that will be appropriately annually to the Animal Welfare Federation of New Jersey (AWFNJ).  http://www.njleg.state.nj.us/2018/Bills/S1000/883_S2.HTM

The funds are mandated “to be used to provide grants to county societies for the prevention of cruelty to animals for the shelter and care of animals.”

While the bill was reported from the Senate Budget and Appropriations Committee, Senator Sarlo, Chair of that committee voted no, saying that he is opposed to this bill, like all others establishing a special license plate, because they all cost the taxpayers money.

Here, there is additional concern because New Jersey has a pre-existing special license described above, established during the Florio administration.  I remember attending the bill signing at Drumthwacket, the official residence of the governor of the State of New Jersey.  The “Animal Friendly” license plate, which debuted in 1994, helps fund “the animal population control program. . . [which] provides low cost spaying and neutering for thousands of pets and encourages the adoption of thousands more each year in New Jersey.”

If enacted into law, this new special plate will dilute the existing animal population program, which had, as of 2012, aided in the spaying and neutering of more than 192,000 cats and dogs, according to then Commissioner of Health, Mary E. O’Dowd.

The funds raised through the [program] support[s] the spay or neutering of dogs and cats adopted from New Jersey shelters, pounds and rescue groups, as well as those owned by persons on public assistance programs.

This fund has been historically popular but runs out of money quickly-many needy families are unable to benefit from the program.

An added benefit of the spay-neuter program, is that it introduces new pet owners to their local veterinarian (who performs the surgery at a greatly reduced fee) and establishes a veterinarian-client-patient relationship that serves as a basis for lifelong veterinary care.

If the State is interested in providing additional funding for animal welfare concerns, this pre-existing program could benefit from additional funds, or perhaps be expanded to assist pet owners without sufficient means provide veterinary care to their pets throughout their lives.

Rescue Road Trips, inc. (the Rescue), as previously described, transports dogs from the south to the northeastern states for sale/adoption.  The Rescue states that

No exchange of payment may occur within the boarders [sic] of the State of Connecticut.

Connecticut, in an attempt to protect consumers and pets, requires animal importers to register with the Commissioner of Agriculture, which the Rescue has done. Connecticut also requires:

“[a]ny animal importer who intends to offer for sale, adoption or transfer any dog or cat at a venue or location that is open to the public or at an outdoor location, including, but not limited to, a parking lot or shopping center, shall provide notice to the Department of Agriculture and the municipal zoning enforcement officer of the town where any such sale, adoption or transfer will occur, not later than ten days prior to such event. Such notice shall state the date for such sale, adoption or transfer event, the exact location of such event and the anticipated number of animals for sale, adoption or transfer at such event. Any person who fails to provide notice as required pursuant to this subdivision shall be fined not more than one hundred dollars per animal that is offered for sale, adoption or transfer at such event.” CT. ST. §22-344(e)(2)

The statute defines “animal importer” as a person who brings any dog or cat into this state from any other sovereign entity for the purpose of offering such dog or cat to any person for sale, adoption or transfer in exchange for any fee, sale, voluntary contribution, service or any other consideration.” CT. ST. §22-344(e)(3).

Is the Rescue attempted to avoid these requirements by arranging for the sale to occur before entering Connecticut?

The Rescue seems to be relying on a fact sheet written by CT Votes for Animals, dated 7/1/2015, titled CT Importation Law Fact Sheet (the Factsheet).

That Factsheet states:

An adopter who intends to keep a cat or dog as a personal companion is not an animal importer if the adopter owns the cat or dog at the time the animal is brought into Connecticut (e.g., the cat or dog is offered on Petfinder and adopted prior to arriving in Connecticut).

It is not clear whether the Rescue, assuming that notification to the State of Connecticut is not required if the transfer of ownership occurs online, before the Rescue enters the State.

But, if the sale/adoption occurs through Petfinder, before entry into the State, that transfer should be considered a non-face-to-face sale by USDA, in which case the Rescue would have to apply for and be approved as a licensee under the Animal Welfare Act. Currently, they describe themselves as an USDA Class T registrant, not as a licensee.

The Factsheet also appears to have other inaccuracies.

For example, it describes importation laws for dogs or cats pursuant to CT. ST. §22-354(a) as “Prior law.” However, currently, CT. ST. §22-354(a) remains in effect.

In addition to these importation provision, CT. ST. §22-344(f), “Veterinary examination of cat or dog imported into state by animal importer,” also requires:

“Any animal importer, as defined in section 22-344, shall, not later than forty-eight hours after importing any dog or cat into this state and prior to the sale, adoption or transfer of such dog or cat to any person, provide for the examination of such dog or cat by a veterinarian licensed under chapter 384. Thereafter, such animal importer shall provide for the examination of such dog or cat by a veterinarian licensed under chapter 384 every ninety days until such dog or cat is sold, adopted or transferred, provided no such dog or cat shall be sold, adopted or transferred to another person by an animal importer unless (1) such dog or cat was examined by a veterinarian licensed under chapter 384 not more than fifteen days prior to the sale, adoption or transfer of such dog or cat, and (2) such veterinarian provides such animal importer with a written certificate stating that such dog or cat is free of any symptoms of any illness, infectious, contagious or communicable disease. Such certificate shall list the name, address and contact information of such animal importer. Any animal importer who violates the provisions of this subsection shall be fined not more than five hundred dollars for each animal that is the subject of such violation.”

The Factsheet, however, replacing the term “provide” with “arrange” states that “the examination itself may occur after the 48 hour period [or] . . . after the 90 day period,” respectively.

That does not appear to be consistent with the statutory language or the legislative history.

The purpose of this provision, adopted in 2011, as summarized in the legislative history, was to, in relevant part, “(1) require a veterinarian to examine a cat or dog within 48 hours of the animal being imported and within 15 days before the sale, adoption, or transfer of the animal.” (emphasis added).

As further described:

“Veterinarian Services and Records Required

The bill requires an animal importer, within 48 hours of importing a cat or dog into Connecticut and before offering it for sale, adoption, or transfer, and every 90 days until the sale, adoption, or transfer is complete, to have a state-licensed veterinarian examine the animal. Each animal must be examined by a state-licensed veterinarian within 15 days before a sale, adoption, or transfer and the veterinarian must provide the animal importer a written health certificate for the animal. An animal importer who violates these provisions is subject to a find of up to $500 for each unexamined or uncertified animal.”

Since the laws in Connecticut were passed to protect human and animal health, at least in part, it is critical that dog sales and/or adoptions are conducted as these provisions require.

 

 

 

Retail rescue organizations like Rescue Road Trips, inc. (the Rescue) who purport to provide “loving, humane road trips to homeless, unwanted, and unloved dogs from Southern Kill Shelters . . . deliver[ed] to Loving ‘Forever Homes’ in New England and surrounding areas,” do nothing to decrease the number of dogs being irresponsibly bred.  They actually do the opposite by facilitating the irresponsible, non-purposeful breeding of dogs.

And, while preventing a dog from unnecessary death is laudable, this operation, like other rescues and some shelters that have largely replaced pet stores and professional breeders as the source of pets in the U.S., this Rescue appears to be quite profitable.

As reported on their website, they have saved over 55,000 dogs to date.  These are dogs moved from southern states to the northeast, where the supply of dogs for sale/adoption does not meet demand, despite statements by HSUS, ASPCA and others claiming that pet store sourcing bans are needed because of the local overpopulation of dogs purportedly caused by pet store sales.

Notably, the justification of a bill recently passed in New York related to regulation of rescues and shelters described the current state of the supply of pets, noting

The number of animals euthanized in U.S. shelters has seen a precipitous decline in the past four decades, from around 15 million annually in the 1970’s to around 3 million currently . . . there are literally hundreds of unregulated entities importing dogs into New York each year . . . [through] the almost 500 incorporated animal groups currently registered with the Office of the Attorney General’s . . . Charities Bureau . . .

The Rescue, reportedly charging $185 per dog per transport―plus another unreported adoption fee per dog―has earned over $10,000,000 in revenues to date.  While there are costs related to transport, the Rescue reports that volunteers pay for the dogs pulled from shelters, and for their medical care, and assists them with canine care along the way, all for no charge to the Rescue.

Think about how that much money could be used to educate dog owners in the south about responsible breeding and provide voluntary spay/neuter programs that have been so effective in many parts of the country, including the northeast.

According to the Rescue’s IRS 990, available on ProPublica’s website, it was formed in 2015, and for that year, revenues totaled $230,000 and the officers reported no working hours or expenses.  Does that mean that they have transported 55,000 dogs since 2016?

To its credit, the Rescue’s “Requirements to Board Transport,” are generally consistent with interstate animal health requirements and sound veterinary medicine, but there may be other concerns about their conduct, particularly in the State of Connecticut, to be discussed further.

Pet therapy programs have been expanding throughout the country, based largely on the increasing recognition that humans benefit from the human-animal bond.  The human-animal bond is defined by the American Veterinary Medical Association as:

a mutually beneficial and dynamic relationship between people and animals that is influenced by behaviors that are essential to the health and well-being of both. This includes, but is not limited to, emotional, psychological, and physical interactions of people, animals, and the environment.

While the IRS, in (PLR 201719018), has recently ruled “that a charity’s planned pet therapy program, which would bring trained therapy dogs to visit hospital patients and elderly nursing home residents, furthers charitable purposes under Section 501(c)(3),” that ruling does not consider or even mention public health concerns related to such programs.

“In support of its ruling, the IRS cited revenue rulings concluding that providing services to hospital patients and other individuals suffering distress in an effort to east that distress and provide them comfort furthers charitable purposes . . . [and] that activities designed to meet the special needs of the elderly may further charitable purposes.”  See Pet therapy program is a Section 501(c)(3) charitable activity, IRS rules (citations omitted).

However, no matter how well intended and “charitable” these programs are, there are serious potential public health risks from exposure of elderly, sick, immunocompromised patients to zoonotic diseases that pets can carry and transmit.  See, e.g., “Diseases you can share with your pets” previously discussed.

Those in the veterinary community understand these risks, as noted by Dr. Lucas Pantaleon, stating, the “[r]isk of zoonoses also arises with therapy dogs in human hospitals. The dogs go through screening but could bring zoonoses from the hospital back into the community.”  See “Speaker: Animal hospitals must practice infection control” reported by Katie Burns, June 1, 2017.

Researchers at Tufts University recently published the results of a “survey of United States hospitals, eldercare facilities and therapy animal organizations revealed their health and safety policies for therapy animal visits varied widely, with many not following recommended guidelines for animal visitation.”  See, “Could Therapy Animal Visitation Pose Health Risks at Patient Facilities?”, June 19, 2017.

The survey included “responses from 45 eldercare facilities, 45 hospitals, and 27 therapy animal organizations across the country on their existing policies related to animal health and behavioral prerequisites for therapy animals and Animal-assisted intervention (‘AAI’) programs.”

Alarmingly, researchers found that many programs had deficient preventive guidelines to at least minimize the potential exposure of zoonotic pathogens from pets to people, finding:

AAI programs have a potential risk of transmission of zoonotic disease—diseases spread between animals and people. This risk is especially high when health, grooming and handwashing protocols are not carefully used. Another potential risk could come from therapy animals eating raw meat-based diets or treats, which are at high risk of being contaminated with bacteria such as Campylobacter, Salmonella and Cryptosporidium. These pathogens may pose risks to both humans and animals, and especially immunocompromised patients.

Zoonotic disease transmission has also been reported in people contracting salmonella from backyard poultry, where almost one third of the 790 victims confirmed by the Centers for Disease Control and Prevention “are children younger than 5 years old.”  See “Salmonella victims from backyard flocks more than double,” Food Safety News, July 14, 2017.

The human-animal bond benefits both people and animals, especially the elderly and children, and should be encouraged.  However, proper protocols and controls should be in place to keep everyone healthy.

 

Like many other animal-related businesses universities, researchers, pharmaceutical companies, their suppliers, associated businesses and non-profit trade associations, are facing increasing scrutiny by the public who seemingly object to the use of animals in research, even though research benefits animals as well as humans.

To address these issues and concerns head on, the New Jersey Association of Biomedical Research recently hosted one of the most significant efforts to promote biomedical research advocacy, the “Biomedical Research Summit,” presented by Bristol-Myers Squibb, also sponsored by Covance, Charles River Laboratories, s-tune software, Inc., Marshall BioResources, and Allentown, Inc. 

Representatives from interested state and national advocacy and professional organizations who are involved in the lab animal research community, as well as representatives from research institutions, including pharmaceuticals, academia and CRSOs, to find common ground and come together on key issues.

Vice-Chair of the NJABR Board of Directors, Laura Conour, DVM, DACLAM facilitated the discussions during the two-day event, encouraging participants to

find ways to enhance the public’s understanding of the critical work undertaken by the biomedical research community and to provide a strong support network for all members in our community, regardless of geography.

The Summit was a huge success, bringing together not only the biomedical research community but also other animal-related sectors under similar attack by animal rights activists.

The following needs and gaps identified include:

  1. A centralized approach for advocacy of biomedical research;
  2. A compelling, consistent, proactive national communication plan;
  3. A comprehensive and effective education effort to address society’s negative perception and lack of understanding about animal research;
  4. There is a lack of an organized and cohesive advocacy effort;
  5. There is a lack of a constituency (a group that support or offers authority and representation) interconnecting with all stakeholders to create a larger network of interests to build and establish effective education efforts; and
  6. Resources are needed to effectuate these goals.

The future of biomedical research advocacy requires a coalescence of all those involved with the humane use of animals for human and animal benefits to educate the public about, not only the necessity of animal use, but also that the animals are treated humanely, and with the understanding that as science advances, the treatment of animals is always evolving to ensure that animals are treated humanely.

Others in the global biomedical research community have launched campaigns in the U.S. and overseas to increase transparency and public education about the special care animals receive in research as well as the incredible importance of their contribution to animal and human health.  For example, as previously discussed, Americans for Medical Progress launched a virtual website “Come See Our World,” where visitors learn about the important role animals play in medical progress.  

Also, the non-profit “Understanding Animal Research” launched a new online tool that allows anyone interested to visit four research facilities in the U.K., through digital video tours.  Participating facilities include the MRC Harwell Institute, The Pirbright Institute, the University of Bristol, and the University of Oxford. 

Understanding Animal Research explains:

why animals are used in medical and scientific research. We aim to achieve a broad understanding of the humane use of animals in medical, veterinary, scientific and environmental research in the UK. We are funded by our members who include universities, professional societies, industry and charities.

 In addition to the virtual lab tours, Understanding Animal Research hosts another website “Concordat on Openness on Animal Research” for “Universities, charities, commercial companies, research councils, umbrella bodies and learned societies [that] have all committed to help the public understand more about animal research.”

Stay tuned for more information about these important developments.

The City Law includes mandatory sterilization requirements for 8 week-old puppies and kittens who weigh at least 2 pounds.

The question is not “can the surgery be performed on a 2 pound 8 week old puppy” but rather, based on the totality of the circumstances, can the veterinarian recommend the procedure for a puppy or dog housed before and after surgery in a pet store and obtain informed consent from the animal’s owner.

For the following reasons, as NYPWA experts and NYC veterinarians testified, the answer is no—not without violating the standards of veterinary practice the State requires.

The State considers it unprofessional conduct if a veterinarian fails to obtain informed consent before proceeding with any medical care or surgery, and has disciplined veterinarians who have failed to obtain informed consent.

The State requires each pet store to designate a veterinarian to provide care to pets in the store, and to provide accepted veterinary standards of care to all pets in pet stores both pre- and post-operative.  This cannot be accomplished if a veterinarian performs the mandatory surgery because, no matter the age, there are environmental stressors in a pet store that, when added to the stress of anesthesia and surgery, will harm animals.  This is most serious for puppies whose immune systems are still developing.

The Law prohibits the transfer of ownership until after the pet is sterilized.  Therefore, the pet must return to the pet store after the surgery for post-operative care, which according to veterinarians is substandard care.

“A pet store is not a suitable environment for post-surgical recovery of baby animals.”  “Post-operative care typically provided by pet owners in their home cannot be performed in a pet store.”

Recently scientists have discovered that early gonadectomy is harmful to pets.  “Gonadectomy prior to puberty or sexual maturity may make the risks of some diseases higher in certain breeds and individuals.”

The American Veterinary Medical Association, the Society for Theriogenology and the American College of Theriogenology are opposed to mandatory sterilization laws for privately-owned pets.  Based on scientific evidence, veterinarians and specialists now recommend delaying sterilization until the first heat to prevent the harm from premature removal of endocrine glands needed for proper growth and certain metabolic disorders and cancer.

According to the Association of Shelter Veterinarians, “A veterinarian should make the final decision regarding acceptance of any patient for surgery . . . [t]he surgeon should use discretion regarding minimum and maximum patient age and body weight taking into account the availability of staff expertise and necessary equipment to care for patients.  Owned pets may be best served by scheduling surgery at 4 months of age or older . . . [i]n situations involving animals that will be placed for adoption, neutering is best performed prior to adoption . . . to ensure compliance.”

The interstate pet market is based on sales of puppies between 8-14 weeks of age, the time for optimal socialization with their owners.  The City’s response to professional objections to early sterilization is that the pet stores should hold onto these puppies for a longer period of time.  According to animal behavior experts “[d]elaying sales as the City has suggested traumatizes the animals [and] increases undesirable behavioral traits that are detrimental to successful lifelong pet ownership.”

For all these reasons, the City Law creates an insurmountable obstacle for pet stores and veterinarians to comply with both the State and City Law, and should be considered preempted by State law.

 

In preparation for the VFD final rule, which outlines the revised process for authorizing use of VFD drugs (animal drugs intended for use in or on animal feed and that require the supervision of a licensed veterinarian), FDA released it’s final version of its industry guidance #233 titled “Veterinary Feed Directive-Common Format Questions and Answers.”

While rejecting a suggestion that FDA require a uniform veterinary feed directive form, FDA has provided a “common VFD format [that] would help veterinarians, their clients (i.e., animal producers), and distributors (including feed mills) quickly identify relevant information on the VFD.”

In addition to providing a list of information that is required, FDA has provided a blank VFD form and several examples of completed forms, several of which are reproduced below.

Blank VFD form
Blank VFD form
Example 1 VFD form
Example 1 VFD form
Example 2 VFD form
Example 2 VFD form

Example 2 VFD form

The information that must be included pursuant to § 558.6(b)(3) on any form utilized includes:

• the veterinarian’s name, address, and telephone number;

• the client’s name, business or home address, and telephone number;

• the premises at which the animals specified in the VFD are located;

• the date of VFD issuance;

• the expiration date of the VFD;

• the name of the VFD drug(s);

• the species and production class of animals to be fed the VFD feed;

• the approximate number of animals to be fed the VFD feed by the expiration date of the

VFD;

• the indication for which the VFD is issued;

• the level of VFD drug in the feed and duration of use;

• the withdrawal time, special instructions, and cautionary statements necessary for use of

the drug in conformance with the approval;

• the number of reorders (refills) authorized, if permitted by the drug approval, conditional

approval, or index listing;

• the statement: “Use of feed containing this veterinary feed directive (VFD) drug in a

manner other than as directed on the labeling (extralabel use), is not permitted.”;

• an affirmation of intent for combination VFD drugs as described in § 558.6(b)(6); and

• the veterinarian’s electronic or written signature.

It would be surprising if veterinarians did not use the forms suggested by FDA to insure they were providing all the information required.

Not everyone is satisfied by the increased restrictions set forth by FDA regarding antibiotics for food animals provided in feed and/or water.

A number of nonprofits filed a citizen petition under section 512(e) of the Food, Drug, and Cosmetic Act, 21 U.S.C. Section 360b(e), “to request that the Commissioner of Food and Drugs withdraw approval of the use of medically important antibiotics in livestock and poultry for disease-prevention or growth-promotion purposes.”

These nonprofits want to prohibit the use of critically important antibiotics that prevent disease in food animals.  Such use is imperative to continue to protect food animals from preventable illness.

By Sheila Goffe originally p

While the zika virus poses worrisome human health concerns, another potential health problem is brewing that threatens both humans and domesticated animals –the importing of foreign dogs for adoption.

Many people are unaware that the U.S. has become something of a favored nation for countries looking to export their rescue dogs due to several reasons.

First, Americans are big-hearted, and when seeking dogs many chose animals made available through rescues.

Second, there’s a readymade market here – Americans love canines and own an estimated 80 million dogs.

The vast majority of imported rescue dogs are not tracked in the United States – either upon arrival or after they enter rescue channels.

Lastly, import rules on dogs can be easily flouted, allowing foreign exporters to send us their sick animals.

The vast majority of imported rescue dogs are not tracked in the United States – either upon arrival or after they enter rescue channels. Patti Strand, founder and national director of the National Animal Interest Alliance, a non-profit that studies shelter trends and the importation of rescue dogs, estimates that close to one million rescue dogs are imported annually from regions not known for stellar canine health and safety standards. They include dogs from Puerto Rico, Turkey, several countries in the Middle East and as far away as China and Korea. That compares to about 8 million dogs annually acquired as pets in the U.S.

All of this underscores that without improved oversight of pet rescue organizations, there’s no way of definitively identifying how many foreign rescue dogs are put up for adoption here.

These foreign rescues may be well-intentioned, but they are courting disaster.

While it is often a challenge to gather information on an abandoned dog here in the U.S., it is even harder for a dog that originated overseas. Information may be missing, poorly translated or unreliable.

Challenges are especially serious when it comes to health and safety. Animals from other countries are not subject to the health and welfare laws of the U.S. and may arrive carrying serious and infectious canine diseases. According to the U.S. Centers for Disease Control and Prevention (CDC), although importation laws require all dogs to be examined by a licensed veterinarian, foreign paperwork is hard to verify and is commonly invalid or forged.

Likewise, the tracking, health and welfare standards that are required for dogs bred in the United States and sold in pet shops do not apply for pets identified as sourced from rescues.

Scores of “puppy mill” bills like New Jersey’s S. 63/A. 2338 that ban pet stores from sourcing professionally-bred pets in lieu of pets sourced from rescues threaten to expand the problem to epic proportions.

The threat to public health is anything but theoretical. On May 30, 2015, eight dogs rescued in Egypt arrived in New York, all but one bound for U.S. rescues. Within days, a dog sent to Virginia became ill and was diagnosed with rabies.

The discovery necessitated an enormous public health investigation involving four state departments of health, three U.S. agencies, the transporting airline and the Egyptian government. Numerous people were interviewed from the airline, rescue organization and veterinarian’s office. In the end, 18 people were vaccinated for rabies either due to direct exposure or concern for possible contact. The rabies vaccination certificate for the dog had been forged, according to the CDC.

This is just one case. The CDC reports a significant uptick in public health concerns and incidents of disease in imported dogs that can be passed between animals and humans.

For example, an outbreak last year in the Midwest of canine influenza that sickened more than 1,100 dogs was traced to the importation of foreign animals, very likely a foreign dog or cat.

“There are multiple international groups who are rescuing dogs from the meat market in Korea and shipping them into the U.S., and we have sketchy quarantine requirements if any at all,” said Dr. Ed Dubovi, director at Cornell University’s Animal Health Diagnostic Center.

Also at issue is the safety and suitability of foreign rescue dogs as family pets. Sources of dogs that are not socialized or bred to be pets are likely to require special handling and training that typical adopters — and even rescues –are not equipped to provide.

Without knowledgeable care, these dogs will end up back in a shelter situation.

Opening our doors is having other undesirable effects. Though some imported dogs are taken by legitimate U.S. rescues, others are becoming the product of unregulated, informal markets, including online retail “rescues.” According to the U.S. Department of Agriculture and U.S. Customs and Border Patrol, there have been numerous incidents involving smuggling of underage and sick animals. Substandard foreign breeders are taking advantage of all of these avenues into the U.S. market, rescue or otherwise.

The importation of rescue dogs does nothing to address issues at the source, and it actually encourages irresponsible breeding overseas. It has created an incentive for irresponsible brokers to round up street animals, buy dogs from Asian livestock markets and allegedly breed animals specifically for export to U.S. rescue markets. And because the animals are labelled as rescues, standards appear to be optional.

A pipeline for unrestricted imports of foreign “rescue” animals undercuts the mission of U.S. rescues, while creating a potential health and safety crisis.

The CDC is exactly correct in its analysis of the problem and its potential risks to Americans.

“Considering the public health risk posed by importation of animals for the purposes of placing them in adoptive homes in the United States, and the current oversupply of adoptable animals already in the United States, persons and organizations involved with importing pets for the purposes of adoption should consider reevaluating, and potentially redirecting, their current efforts,” the agency wrote.

Plenty of domestic dogs are languishing in shelters and in need of homes. Our duty is to help these dogs first.

Sheila Goffe is Vice President, Government Relations for the American Kennel Club. Follow the AKC on Twitter @akcdoglovers.