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New APHIS (USDA) regulations regarding those who breed and sell dogs


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#1 Eileen Stein

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Posted 10 September 2013 - 10:56 PM

Some of you will remember that last year APHIS (USDA) proposed modifying its rules governing who must be licensed under the Animal Welfare Act as a "Dealer," and thereby become subject to federal licensing and regulation requirements.  The proposal was discussed in several threads at the time, including this one, and several Boards members submitted comments, as did the ABCA.

 

Today APHIS issued the final regulations.  They are substantially unchanged from what was originally proposed.  I've read the 91 pages of APHIS comments that accompanied them, and was on the line for a conference call (thanks for the heads-up, Deb Meier) earlier today at which APHIS announced the new regs, and took some questions (call lasted less than 45 minutes, they didn't get to me).

 

Based on all that, this is what I take away (simplifying a little, but not where it matters):

 

You are exempt from licensing and regulation if you don't sell any dogs to be used as pets, ever. Questions were raised as to how APHIS would interpret that -- suppose you breed for work, but occasionally you sell a dog that ends up being used as a pet, or unbeknownst to you is used as a pet, etc.?  They said several times that with regard to enforcement "it comes down to your business model."  If you're marketing them as working dogs and all your breeding and advertising is consistent with that, and the vast majority of your sales are consistent with that, then you're unlikely to be targeted.  (So don't add on your website "And they make great pets, too!")  They said that dogs sold for dual purposes (pet and X) will be considered pets.  Dogs bred and sold for agility are considered pets.  With regard to the meaning of "sell," they said that rescues that collect adoption fees are considered to be selling dogs within the meaning of the regs. 

 

Even if you sell dogs to be used as pets, you still are not subject to regulation if you fall within the definition of a "retail pet store."  To meet that definition under the proposed regs, everyone who bought a dog from you had to come to your place of business or residence and see the dog in connection with the purchase; if you ever sell a dog to anyone who doesn't come to your premises, you could not qualify.  The final regs say pretty much the same thing, but APHIS is interpreting them to give more latitude than that.  (Writing regs that say one thing and then saying you're going to interpret them to say something different is one reason people hate lawyers, IMO, and why even lawyers hate administrative law.)  As long as the buyer, seller and dog are together in one place "face to face" at the time of the purchase and/or the time the buyer takes custody of the dog, that is sufficient for the seller to meet the definition of a retail pet store, and be exempt.  So the way they are interpreting it, you can deliver the dog to the buyer (and maybe even to an agent of the buyer, who they will consider to be the buyer) at a trial or clinic, or (to take a darker example) in a Walmart parking lot, and still be a retail pet store and therefore not subject to licensure/regulation.  They say that this will exempt most rescues, whose "business model," they say, is to have a representative of the rescue deliver the dog to the new owner at an adoption fair or the like.  But if you (breeder or rescue) ever ship even one dog, or sell it when you, the "buyer" and the dog are not all in the same place at the same time, you cannot take advantage of this "retail pet store" exemption.

 

The only other way to avoid the regulation/licensure requirements if you ever sell a dog is if you have no more than four "breeding females" on your premises AND you never sell a dog that you did not breed and raise on your premises.  Dogs, cats and small exotic or wild mammals all count toward the total, and it doesn't matter if you own some and another family member owns the others; they will all be aggregated.  "Breeding females" is not defined in the regs, but they say they interpret it to mean "capable of being bred," whether or not the dogs are or have been bred.  They say it will be up to their inspectors to decide if an animal is a breeding female, and the inspectors will make this decision based on considerations like age and health, but with no specific or additional guidelines.  This would be fun to challenge, from a lawyer's point of view, but leaves the breeder with no certainty in advance as to whether s/he qualifies for this exemption or not, when the whole point of regs is to provide certainty about what the law requires.  Most working breeders probably could not meet this exemption in any case, however, because it would be rare for one to never sell a single dog that was not born and raised on their premises.

 

Regarding enforcement, APHIS said that they will monitor ads and internet sites, and perhaps even contact them asking things like "Do you ship?"  They will look first to those facilities selling the most dogs, and those against whom credible complaints have been made.  All inspections will be by USDA inspectors.

 

That's about the size of it.  If APHIS is spread as thin, enforcement-wise, as I'm guessing they are, this might not end up being such a bad thing -- they'll prioritize the big bad breeders and not even notice our good, much more small-scale, breeders.  But even if that's how it turns out, it's a crummy rule change-- badly drafted, not well-fitted to what it's supposedly trying to achieve, and intellectually dishonest.    



#2 Debbie Meier

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Posted 10 September 2013 - 11:15 PM

Glad you were able to get in on the conference call


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#3 Sue R

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Posted 11 September 2013 - 05:38 AM

This looks like a nightmare for many very responsible working dog owner/breeders and for rescues that do charge an adoption fee (which is a reasonable thing for them to do, considering the funds they have put into many of their rescue dogs).  

 

Thank you, Deb and Eileen, for the heads-up.  


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#4 Olivia

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Posted 11 September 2013 - 06:31 AM

From the perspective of E. TN Border Collie Rescue... Fabulous!  (sarcasm)  I can count on one hand the number of times we have shipped a dog but it has happened.  Sigh.  I guess we are going to have to remember that we can no longer do that.



#5 GentleLake

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Posted 11 September 2013 - 09:20 AM

Thanks for the great summary, Eileen.

 

May I forward it to the rescues I'm affiliated with?

 

Thanks.

 

roxanne



#6 gcv-border

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Posted 11 September 2013 - 09:35 AM

Another thanks for this information. Just incredible (yes, sarcasm).

Who/What is behind these new regs? Animals rights groups? Others?

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#7 GentleLake

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Posted 11 September 2013 - 10:02 AM

I suspect that the intentions are good, but that like most government endeavors it's just not well thought out.

 

Like California's new regs that puppies have to have rabies vax at 3 months old . . . the intent, I'm sure, is to help stop rabies (duh!), but the science just doesn't support it. 

 

I simply don't understand how these people continue to get reelected.  :wacko:



#8 Eileen Stein

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Posted 11 September 2013 - 10:30 AM

Roxanne -- Yes, feel free to forward.

 

Jovi -- Yes, animal rights and animal welfare groups, chiefly HSUS and the Doris Day Animal League. 



#9 GentleLake

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Posted 11 September 2013 - 10:56 AM

Thanks, Eileen.

 

 

The only other way to avoid the regulation/licensure requirements if you ever sell a dog is if you have no more than four "breeding females" on your premises AND you never sell a dog that you did not breed and raise on your premises.  Dogs, cats and small exotic or wild mammals all count toward the total, and it doesn't matter if you own some and another family member owns the others; they will all be aggregated.  "Breeding females" is not defined in the regs, but they say they interpret it to mean "capable of being bred," whether or not the dogs are or have been bred.  They say it will be up to their inspectors to decide if an animal is a breeding female, and they will make this decision based on considerations like age and health, but with no specific or additional guidelines. 

 

So, essentially you could have one breeding female dog (or cat), but have a female parakeet, 2 female gerbils and a female tarantula (which you never breed, but who neuters parakeets, gerbils and tarantulas?).   And if some local official has a bug up his or her butt about you because they don't like how often you mow your lawn or your kids don't get along in school they could interpret this technically as your having more than 4 breeding females?  So when you breed your female dog (or cat) one time and then ship a puppy or kitten, you could be cited?

 

Who writes this kind of idiotic and vague regulations?



#10 Gloria Atwater

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Posted 11 September 2013 - 11:24 AM

Are or will the regulations be online for us to read, at some point? I was all over the USDA website last night and couldn't find anything. In fact, the one link to regulations that I did find went to a 404 Error page, so maybe they're updating?

I really want to read the actual language, though. I want to be informed as to what the words REALLY say, so we can beware of how inspectors or whomever might translate them.  The 'breeding females" thing is crazy-making. I could have two intact bitches, an un-spayed feral barn cat and two guinea pigs, and suddenly I'm over limit!

But if I'm reading this right, the goal of working-dog breeders should, therefore, be to qualify as "retail stores" who do NOT sell pets. Is that correct?

I'd still want to read the language as to what defines a retail store, and whether there are specific criteria a breeder should meet, besides having all buyers meet them and the puppy face-to-face.

Plus, I want to read the regulations and descriptions of what a USDA licensed kennel should be. I know I read them somewhere some months ago, but I guess I didn't save the bookmark. I want to read again the language about non water-permeable surfaces, etc., because at the time it read like they were describing what many folks consider a puppy mill! A big, industrial-grade kennel. Can anyone direct me to that document, wherever it is?

 

Also, am I imagining things, or did I read of requirements that would keep bitches and pups in strict isolation from all other dogs?  (Along with the non water-permeable, steam-cleanable stuff.)

What they say they'll interpret and what some inspector may decide to do are apt to be very different things. It sounds ... at least somewhat better, but I don't trust it.

Thanks for all the info, Eileen!  Definitely appreciate you going to the trouble and sharing the info.  :)

~ Gloria


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#11 Stoga

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Posted 11 September 2013 - 11:24 AM

Thanks for interpreting/translating, Eileen...


Donna

#12 Gloria Atwater

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Posted 11 September 2013 - 11:27 AM

P.S.
The bit about selling a dog not born on the premises ... It only applies to breeders, right? Because it would suck if selling ANY dog not born on the property meant one was therefore required to be USDA licensed ....


You ask of my companions. Hills, sir, and the sundown, and a dog as large as myself that my father bought me. They are better than human beings, because they know but do not tell. ~ Emily Dickinson

To sit with a dog on a hillside on a glorious afternoon is to be back in Eden, where doing nothing was not boring - it was peace. ~ Milan Kundera

#13 Eileen Stein

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Posted 11 September 2013 - 12:33 PM

Gloria, you can find the entire regulations, as they were before yesterday's changes, here.  Note the definition of "Impervious surface."  Yes, they are obviously written for large breeding operations, implementing an act (the Animal Welfare Act) which was also aimed at large breeding operations.

 

Here is the full text of the changes made yesterday:

 

PART 1--DEFINITION OF TERMS 
 1. The authority citation for part 1 continues to read as follows: 
 Authority: 7 U.S.C. 2131-2159; 7 CFR 2.22, 2.80, and 371.7. 
 2. In § 1.1, the definitions of dealer and retail pet store are revised to read as follows: 
§ 1.1 Definitions. 
* * * * * 
 Dealer means any person who, in commerce, for compensation or profit, delivers for 
transportation, or transports, except as a carrier, buys, or sells, or negotiates the purchase or sale 
of: Any dog or other animal whether alive or dead (including unborn animals, organs, limbs, 
blood, serum, or other parts) for research, teaching, testing, experimentation, exhibition, or for 
use as a pet; or any dog at the wholesale level for hunting, security, or breeding purposes. 
This term does not include: A retail pet store, as defined in this section; any retail outlet where 
dogs are sold for hunting, breeding, or security purposes; or any person who does not sell or 
negotiate the purchase or sale of any wild or exotic animal, dog, or cat and who derives no more 
than $500 gross income from the sale of animals other than wild or exotic animals, dogs, or cats 
during any calendar year. 
* * * * * 89 
 Retail pet store means a place of business or residence at which the seller, buyer, and the 
animal available for sale are physically present so that every buyer may personally observe the 
animal prior to purchasing and/or taking custody of that animal after purchase, and where only 
the following animals are sold or offered for sale, at retail, for use as pets: Dogs, cats, rabbits, 
guinea pigs, hamsters, gerbils, rats, mice, gophers, chinchillas, domestic ferrets, domestic farm 
animals, birds, and coldblooded species. In addition to persons that meet these criteria, retail pet 
store also includes any person who meets the criteria in § 2.1(a)(3)(vii) of this subchapter. Such 
definition excludes— 
(1) Establishments or persons who deal in dogs used for hunting, security, or breeding 
purposes; 
(2) Establishments or persons, except those that meet the criteria in § 2.1(a)(3)(vii), 
exhibiting, selling, or offering to exhibit or sell any wild or exotic or other nonpet species of 
warmblooded animals (except birds), such as skunks, raccoons, nonhuman primates, squirrels, 
ocelots, foxes, coyotes, etc.; 
(3) Any establishment or person selling warmblooded animals (except birds, and 
laboratory rats and mice) for research or exhibition purposes; 
(4) Any establishment wholesaling any animals (except birds, rats, and mice); and 
(5) Any establishment exhibiting pet animals in a room that is separate from or adjacent 
to the retail pet store, or in an outside area, or anywhere off the retail pet store premises. 
* * * * * 
PART 2--REGULATIONS 
 3. The authority citation for part 2 continues to read as follows: 90 
 Authority: 7 U.S.C. 2131-2159; 7 CFR 2.22, 2.80, and 371.7. 
 4. Section 2.1 is amended as follows: 
 a. By revising paragraph (a)(3)(i); 
 b. In paragraph (a)(3)(ii), by removing the words ''to a research facility, an exhibitor, a 
dealer, or a pet store''; 
 c. By revising paragraphs (a)(3)(iii) and (a)(3)(vii); and 
 d. In the OMB citation at the end of the section, by removing the words ‘‘number 0579-
0254’’ and adding the words ‘‘numbers 0579-0254 and 0579-0392’’ in their place. 
The revisions read as follows: 
§ 2.1 Requirements and application. 
 (a) * * * 
 (3) * * * 
 (i) Retail pet stores as defined in part 1 of this subchapter; 
* * * * * 
 (iii) Any person who maintains a total of four or fewer breeding female dogs, cats, and/or 
small exotic or wild mammals, such as hedgehogs, degus, spiny mice, prairie dogs, flying 
squirrels, and jerboas, and who sells, at wholesale, only the offspring of these dogs, cats, and/or 
small exotic or wild mammals, which were born and raised on his or her premises, for pets or 
exhibition, and is not otherwise required to obtain a license. This exemption does not extend to 
any person residing in a household that collectively maintains a total of more than four breeding 
female dogs, cats, and/or small exotic or wild mammals, regardless of ownership, nor to any 
person maintaining breeding female dogs, cats, and/or small exotic or wild mammals on 
premises on which more than four breeding female dogs, cats, and/or small exotic or wild 91 
mammals are maintained, nor to any person acting in concert with others where they collectively 
maintain a total of more than four breeding female dogs, cats, and/or small exotic or wild 
mammals regardless of ownership; 
* * * * * 
 (vii) Any person including, but not limited to, purebred dog or cat fanciers, who 
maintains a total of four or fewer breeding female dogs, cats, and/or small exotic or wild 
mammals, such as hedgehogs, degus, spiny mice, prairie dogs, flying squirrels, and jerboas, and 
who sells, at retail, only the offspring of these dogs, cats, and/or small exotic or wild mammals, 
which were born and raised on his or her premises, for pets or exhibition, and is not otherwise 
required to obtain a license. This exemption does not extend to any person residing in a 
household that collectively maintains a total of more than four breeding female dogs, cats, and/or 
small exotic or wild mammals, regardless of ownership, nor to any person maintaining breeding 
female dogs, cats, and/or small exotic or wild mammals on premises on which more than four 
breeding female dogs, cats, and/or small exotic or wild mammals are maintained, nor to any 
person acting in concert with others where they collectively maintain a total of more than four 
breeding female dogs, cats, and/or small exotic or wild mammals regardless of ownership. 
* * * * * 
 
You'll see what I mean that the definition of "retail pet store" speaks of "a place of business or residence at which seller, buyer and the animal available for sale" are all together.  In fact, it explicitly excludes (in subsection (5)) "Any establishment exhibiting pet animals in a room that is separate from or adjacent 
to the retail pet store, or in an outside area, or anywhere off the retail pet store premises."  So how can a face to face meeting at some location "off the retail pet store premises" qualify you as a retail pet store?  Through the magic of creative administrative interpretation -- "We don't want to hold to the definition we've written here, but we want to pretend we are."  Not that I'm against the result that lets breeders transfer a pup to a buyer at a trial and still qualify for the retail pet store exemption; I'm just saying the means by which they achieve that result is disreputable.
 

But if I'm reading this right, the goal of working-dog breeders should, therefore, be to qualify as "retail stores" who do NOT sell pets. Is that correct?

 
Well, if they never, ever sell a pup or dog for use as a pet, they don't need to qualify as retail pet stores.  They're free and clear.  But if they do sell a pet now and then, then their goal should be to qualify as a "retail pet store" and get that exemption.
 
And here, for good measure, is the actual Animal Welfare Act, the federal law that these regulations are implementing.


#14 Eileen Stein

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Posted 11 September 2013 - 01:11 PM

P.S.
The bit about selling a dog not born on the premises ... It only applies to breeders, right? Because it would suck if selling ANY dog not born on the property meant one was therefore required to be USDA licensed ....

 

Ah, beware of assumptions.   ;)   A "dealer" is defined in the AWA as "any person who, in commerce, for compensation or profit, . . . sells, or negotiates the purchase or sale of, (1) any dog or other animal. . . for . . . use as a pet . . . except that this term does not include . . . a retail pet store. . . ." [Emphasis added.]  

 

And the Act goes on to provide that:

 

No dealer . . . shall sell or offer to sell or transport or offer for transportation, in commerce, . . . for use as a pet any animal, . . . unless and until such dealer or exhibitor shall have obtained a license from the Secretary and such license shall not have been suspended or revoked. [Emphasis added.]

 

The regulations say essentially the same thing.

 

But APHIS is not going to come after you for selling only one dog, whether born on your premises or elsewhere, if only because they wouldn't want to have to litigate the issue of whether your little sale affects interstate commerce enough to justify federal regulation.  And if you deliver that one dog in person you're safe, no matter what, because then you're a retail pet store!   :P  No wonder everyone loves the government!       



#15 gonetotervs

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Posted 14 September 2013 - 08:13 AM

You know, as a non-breeder and a puppy buyer who also has two rescues, I'm not really opposed to this legislation if it manages to inhibit our local puppy-millers. I normally plan contacting a breeder between 12 and 24 months before I expect to be ready for puppy, and I drove 7 hours to get the last rescue. I'm not sure that everyone on this list would want me as a puppy buyer, but I'm pretty sure that a lot of you would not reject me out of hand -- and if I end up paying for a extra day in hotel/more gas to meet in person -- so be it. I can budget for that. My adolescent idiot boy bit off part of his tongue this month and needed emergency surgery -- an item not in the budget but nonetheless paid for gladly to my very accomodating vet.

We have WAY too many perfectly nice dogs put down in this country because people make impulse decisions and some people think to make a quick buck off their dogs. I know you can't legislate stupid, but maybe if you make impulse decisions more unlikely, you can help the dogs. Just don't get me started on our local Amish.... but I do approve of the government trying to take on puppy millers in the teeth of the AKC. And thinking back -- I've never bought a puppy off of a breeder who had more than 4 breeding females( though I never counted cats/gerbils/etc. so maybe that's not true.)

#16 Eileen Stein

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Posted 14 September 2013 - 11:15 AM

Bear in mind that APHIS has said they will count healthy, intact females old enough to breed as "breeding females" whether or not they are actually being bred.  A lot of our good breeders take dogs in for training, or train dogs up for sale to livestock producers, so they are very likely to be "maintaining"  more than four "breeding females" at any one time (dogs count even if you don't own them, if they're living with you).  Bear in mind that they also are likely to sell an occasional dog they have not bred, which automatically deprives them of the "four breeding females" exemption even if they have only one breeding female.  And too, while you may be able to up your travel time and budget significantly, many a livestock farmer cannot.  That doesn't make him/her an impulse purchaser.

 

I totally agree that we have way too many perfectly nice dogs put down in this country, for the reasons you state and others as well.  And there's no doubt that this rule change has been marketed as a tool for solving that problem -- a problem which pretty much everyone supports solving.  My problem with these specific regs (not with their stated aim) is that they are very poorly designed to accomplish their stated aim, and if enforced as written would do more harm to working border collies and good breeders of working border collies than any good they are likely to do.  I could get behind a well-designed law or rule that would require sellers of more than X number of dogs per year to be licensed. But with these regs, the closer you study them and the more you learn about them, the more apparent their glaring faults are.  Saying they're intended for a good purpose is not good enough.    



#17 GentleLake

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Posted 14 September 2013 - 11:24 AM

^^Very well said, Eileen.

 

I think the intent of this legislation is admirable.  It's the way they've chosen to go about implementing that intent that hasn't been particularly well thought out.

 

Yeah . . . it's no wonder everyone loves the government.  <sigh>



#18 MrSnappy

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Posted 14 September 2013 - 11:38 AM

I'm a bit bleary as it's first thing in the morning, but maybe someone could theorize for me on whether this would summarily halt the export of vast numbers of dogs from US shelters up to Canada?  Or would this only be affected if the rescues were receiving funds from the Canadian rescuers on the receiving end?  I admit I did not read the whole post, so this may be a stupid question.  But I need coffee before I can delve into anything complicated on my day off.

 

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#19 Eileen Stein

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Posted 14 September 2013 - 09:47 PM

Not a stupid question at all.  If the dogs are coming from government shelters (county, municipal, etc.), these regs would have no effect.  If the dogs are coming from private rescues, and the rescues are either receiving money for them or transporting them, theoretically there would be a big effect.  Those rescues will now be "Dealers" under the Act.  So they would need to be licensed unless all their transactions are "face-to-face."  If their only transactions that are not face-to-face are those shipments to Canada, they might be well-advised to stop shipping rather than to take on the burdens of licensure and regulation.  I don't think the fact that the dogs end up in Canada would affect the requirement that they be licensed.  But I suppose they might just decide to keep operating as they have been and hope APHIS doesn't become aware of them and come after them.  




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