I received a reply from my email to the Vet Assoc of PA regarding this bill. It is long, but interesting.
To Those Individuals that Have Expressed Concern about Our Position on HB
2525 -
The Reality of PVMA's Position on the "Puppy Mill" Bill
PVMA Does Support HB 2525 - "The Puppy Mill Bill"
You can't pick up a newspaper, read one online, listen to radio, watch the
news - or for that matter "Oprah" - without hearing about Pennsylvania's
legislation to stop the "puppy mills." This highly emotional and heated
debate has resulted in the misrepresentation and outright lies about the
Pennsylvania Veterinary Medical Association (PVMA), the Association's
positions, and its motives for weighing in on the bill, HB 2525. Some have
even taken it as far as waging a smear campaign about PVMA and personally
attacking people within PVMA leadership - going as far as putting personal
phone numbers and email addresses out on listserves. These adversarial
conditions come at a time when the stakeholders interested in improving the
bill - including PVMA - should be working together toward everyone's common
goal - to create a better environment for the dogs housed in commercial
breeding kennels. Instead, we are faced with mud slinging and ugliness.
PVMA and the veterinary profession are only concerned about one thing
related to this piece of legislation, ensuring that it will result in a
better environment, better and readily available veterinary care, and
enforceable measures that protect the welfare of the dogs housed in the
commercial breeding kennels. PVMA leadership is not motivated by financial
gain from commercial breeders nor sick puppies or dogs. To say that is not
only an insult to the veterinary profession but an outright lie. PVMA and
the veterinary profession, which PVMA represents, is dedicated to ensuring
the welfare of all animals and takes an oath to protect and care for
animals. The profession and the Association are also held to professional
and personal ethical standards, both of which are taken very seriously.
Why Are People Saying PVMA is Trying to Stop the Legislation?
There are those who continue to state that PVMA is trying to stop the
legislation. This is untrue. PVMA had five main concerns with the
legislation that Association has worked to address with the appropriate
people in the House of Representatives, the Senate, and the Governor's
office to make it a better bill, one that will result in what everyone
wants: an improved life for the dogs. These bodies are in charge of this
legislation and hearing the concerns of constituents and stakeholders like
PVMA. Our position was sought by legislators as animal health experts and
other than the welfare of the dogs at commercial breeding kennels, we don't
have a "dog in this fight," so to speak.
From the beginning of the process to make this legislation law, we have been
in full support of the following:
. Doubling cage size
. Annual veterinary exams
. A written program of veterinary care
. Establishment of a Veterinarian-Client-Patient Relationship and
related responsibilities between the veterinarian and the kennel operator
. Exercise outside of the primary enclosure
. Establishing scientifically based and measurable standards for
ventilation, ambient temperature, and relative humidity
. Lighting standards for the kennel facilities
. Access to water at all times
. Euthanasia only by a veterinarian
PVMA has been working with the Pennsylvania Department of Agriculture (PDA)
on their proposed remedy to the Dog Law Reform since they attempted to clean
up the commercial breeding industry through a regulatory package almost
three years ago. That package resulted in over 16,000 comments, the most
ever received by a state agency on a single issue. Even before the
introduction of this regulatory package, PVMA was represented by
veterinarians working on a Committee of Veterinarians appointed by the
Governor to start addressing his concerns with the industry and the
effectiveness of the Dog Law Advisory Board. Following that, the Department
decided to attempt the reform via the legislature. From the beginning of
this process, PVMA has met with the PDA and the Governor's legislative staff
to review preliminary drafts of the proposal, and continued to meet up to
and following the introduction of HB 2525 and HB 2532 in the House of
Representatives this past May. Once introduced, it became obvious that
these bills were on the fast track to being considered and passed.
Since May, when this immense bill (now 91 pages) was introduced, PVMA has
been working hard to represent the veterinary profession and what is in the
best interest of the health and welfare of the dogs housed in commercial
breeding kennels. The Association has continued to work with PDA, the
Governor's office, the House of Representatives, and the Senate to address
legitimate concerns.
Why Hasn't PVMA Spoken in the Public Forum Until Now?
PVMA has provided comments on HB 2525 and HB 2532 to the interested media
when they have called on the Association for its input. Much of what has
been posted on the Internet, passed around in discussion forums, and
independently reported in the media about PVMA's position has been skewed,
misrepresented, or taken out of context.
Rather than engage in mudslinging with people who are not responsible for
the movement of this bill, PVMA has focused its attention and efforts on
working to address the Association's concerns with legislators, the
Administration, and all stakeholders willing to discuss the issues while
remaining professional, respectful, and dedicated to the welfare of the
dogs.
Is PVMA Supporting the Interests of the Commercial Breeding Industry?
PVMA has purposefully stayed out of any debates or discussions on issues
outside of the realm of animal welfare and there are many issues related to
this bill including constitutionality concerns and property rights. PVMA
weighed in on this legislation only because of the welfare and health
provisions outlined in the bill.
PVMA has been accused of somehow profiting from the commercial breeding
industry and having less than honest motives. This is not the case. PVMA,
as an association and as a profession, live and work by professional and
personal ethical standards. PVMA has met with various stakeholders on this
legislative bill over its course in the General Assembly as well as the
Administration, House of Representatives, and the Senate. PVMA leadership
is open to meeting and considering any stakeholder's position. However, at
the end of the day, the Association does not represent anyone's interests
but those of the animals we serve and the veterinary profession.
PVMA has been working with the commercial breeding industry for over a year
to investigate the feasibility of a voluntary quality assurance program for
the dogs housed in breeding kennels. Why? Because of concern over the
welfare of the dogs and the potential positive impact that helping the
breeders would have on the dogs. There is no financial gain by doing so.
In fact, the program has only been discussed in concept to date because of
focusing on HB 2525 and the impact that will have on the program.
What about Flooring and Exercise?
Solid Flooring
Solid flooring creates unsanitary conditions for the dogs housed in
commercial breeding kennels. Even with diligent efforts to keep the primary
enclosure clean, multiple dogs (6 are allowed in a primary enclosure in the
bill) urinating and defecating on the floor at various times during a
24-hour period make it impossible to ensure that the primary enclosure will
remain clean thus exposing the dogs to unsanitary and unsafe conditions for
their health. Resting boards were eliminated from the Pennsylvania Dog Law
because of this issue. Even with the allowance for a small wire floor area
in the primary enclosure, the dogs will still urinate and defecate on the
solid floor area. They are not otherwise trained.
PVMA has never supported uncoated wire flooring as seen in many photos of
the dogs in puppy mills nor any flooring that allows the feet of the dog to
pass through and cause injury to the dog. Much of this would already be out
of compliance with the current law. PVMA is in favor of flooring that
provides moderate drainage, does not bend or sag under the weight of the
dogs, is kept in good repair, and does not allow the feet of the dogs to
pass through or cause injury in any way. There are many variations between
wire flooring and solid flooring; the 2 extremes. PVMA advocates for
flooring that allows for moderate drainage and will meet certain conditions
that would ensure the safety and welfare of the dogs.
PVMA supports the current amendment offered by Senator Brubaker that would
allow for a slatted floor which would provide for moderate drainage. For
the health and well-being of the dogs, that is preferred over the solid
flooring. However, because there are additional options being offered in
this amendment, PVMA supports it 100%.
Exercise
PVMA supports the requirement of unfettered access to an exercise area or
run outside of the dogs' primary enclosure. Regular exercise and
socialization are important factors in the overall welfare of dogs. PVMA has
concerns that extreme temperatures throughout the year do not create a good
environment for the dogs and their tolerance for extreme weather conditions
varies by breed. In addition, pest control and temperature control within
the building can become issues with open doors to the outside runs. PVMA
does support Senator Brubaker's amendment related to exercise which would
require that exercise be outdoors unless prohibited by a local ordinance.
However, if exercise runs are to be mandated outdoors, the Association would
like snow and ice removal in the runs and pest and temperature control (use
of draft-free "doggie doors") to be addressed. The amendment also allows
for a veterinarian to make medical judgments related to exercise for dogs
that may be sick, injured or otherwise have special needs. PVMA supports
this provision. PVMA does not support the USDA allowance of placing 2 dogs
in a cage as an accepted exercise plan.
Our Other Concerns
Rabies Vaccinations
PVMA supports Senator Brubaker's amendment to change the bill to make
administration of rabies vaccines consistent with the current rabies law
which allows rabies vaccines to be administered by or under the supervision
of a licensed veterinarian. Currently, rabies vaccinations are allowed to be
administered by commercial breeding kennel operators who have been trained
and certified by the Pennsylvania Department of Agriculture. PVMA sees no
reason why the kennel operators who are certified to do so should not be
allowed to administer rabies vaccinations under the supervision of a
licensed veterinarian.
Temperature and Ventilation
PVMA supports the provisions related to temperature and ventilation but
would like a more scientifically based measurement or combination of
measurements of ammonia levels, relative humidity, and ambient temperature
to be used to determine adequate ventilation. Adequate ventilation is even
more important than temperature control because even on very hot or very
cold days, proper ventilation will ensure that the facilities are kept
comfortable and healthy for the dogs.
Canine Health Advisory Board
PVMA support Senator Brubaker's amendment calling for a Canine Health
Advisory Board to help create regulations related to acceptable ranges for
ambient temperature, ventilation, relative humidity, and ammonia levels,
lighting, and flooring variances. PVMA has concerns about the composition
of the Board but overall supports the concept of having veterinary expertise
involved in these discussions related to such important welfare provisions.
What About HB 2532?
PVMA supports HB 2532, the amendments to the Animal Cruelty Statute, as
passed by the House of Representatives including the provisions related to
tail docking, dewclaw removal and caesarian birth.
For More Information
Please visit our website for more information at
www.pavma.org. Feedback or
questions can be sent to Charlene Wandzilak, Executive Director, at
[email protected].
Thank you for your concern. I hope this clarifies our position. We all want
what is best for the dogs in commercial breeding kennels and hopefully, HB
2525 will accomplish that and PVMA is no exception. This legislation is a
step in the right direction.
Sincerely yours,
Charlene Wandzilak
Executive Director
Pennsylvania Veterinary Medical Association
