Danger to Your Rabbitry - PAWS Legislation

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 http://saova.org/1139.html 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 www.vote-smart.org 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.

Rob Usakowski is owner of Three Little Ladies Rabbitry which is run by his

wife Cathie and their three daughters. Visit their site www.threelittleladiesrabbitry.com for lots of rabbit raising information for both pet owners and

breeders alike.