terrecar Posted June 20, 2012 Report Share Posted June 20, 2012 There just seems to me to be something very 'wrong-headed' about limiting breeders who have a goal other than making money, even if the fallout from the new regs is incidental. If this were only about standards of care, I would support it. However, if it gives breeders whose goal it is to make a buck an advantage over those who engage in thoughtful, selective breeding, then in my opinion we are going backwards. ETA: An example: Let's take a volume breeder who breeds for money (I started with a show breeder example but I will leave that alone). These regulations will give him an advantage over lower volume, careful breeders who would rather not have their personal space (home) inspected and who have more than 4 intact females of breeding age (if that is the way the regs end up defining "breeding female"). His "economies of scale" allow for a separate facility and kennel help, and now these regulations have cut out some of his competition. I don't want to give him that advantage. Quote Link to comment Share on other sites More sharing options...
Debbie Meier Posted June 20, 2012 Report Share Posted June 20, 2012 From the transport area.... "The ambient temperature must not fall below 45 °F (7.2 °C) for more than 4 consecutive hours when dogs or cats are present, and must not exceed 85 °F (29.5 °C) for more than 4 consecutive hours when dogs or cats are present. " We are going to have to purchase a new dog trailer.....our trailer does not have heat and is only equiped with a fan for the summer. Quote Link to comment Share on other sites More sharing options...
Debbie Meier Posted June 20, 2012 Report Share Posted June 20, 2012 (d) Water and electric power. The housing facility must have reliable electric power adequate for heating, cooling, ventilation, and lighting, and for carrying out other husbandry requirements in accordance with the regulations in this subpart. The housing facility must provide adequate running potable water for the dogs' and cats' drinking needs, for cleaning, and for carrying out other husbandry requirements Does a 150 foot garden hose strung across the yard from the front well head back to the kennel count? If not then we will have to dig some new water lines...and are they saying automatic waterers? That will require us to put heat into our kennel buildings $$$$ Quote Link to comment Share on other sites More sharing options...
Debbie Meier Posted June 20, 2012 Report Share Posted June 20, 2012 Housing facilities must be equipped with disposal facilities and drainage systems that are constructed and operated so that animal waste and water are rapidly eliminated and animals stay dry. Disposal and drainage systems must minimize vermin and pest infestation, insects, odors, and disease hazards. All drains must be properly constructed, installed, and maintained. If closed drainage systems are used, they must be equipped with traps and prevent the backflow of gases and the backup of sewage onto the floor. If the facility uses sump or settlement ponds, or other similar systems for drainage and animal waste disposal, the system must be located far enough away from the animal area of the housing facility to prevent odors, diseases, pests, and vermin infestation Ok, our one kennel is 4 bay the other is 5, I hose the outside and let it drain to the grass and into the driveway I don't think that is going to fly.....let's see, what is it going to cost to add gutters, drains and then a leech field? Quote Link to comment Share on other sites More sharing options...
Debbie Meier Posted June 20, 2012 Report Share Posted June 20, 2012 § 3.2 Indoor housing facilities.(a) Heating, cooling, and temperature. Indoor housing facilities for dogs and cats must be sufficiently heated and cooled when necessary to protect the dogs and cats from temperature or humidity extremes and to provide for their health and well-being. When dogs or cats are present, the ambient temperature in the facility must not fall below 50 °F (10 °C) for dogs and cats not acclimated to lower temperatures, for those breeds that cannot tolerate lower temperatures without stress or discomfort (such as short-haired breeds), and for sick, aged, young, or infirm dogs and cats, except as approved by the attending veterinarian. Dry bedding, solid resting boards, or other methods of conserving body heat must be provided when temperatures are below 50 °F (10 °C). The ambient temperature must not fall below 45 °F (7.2 °C) for more than 4 consecutive hours when dogs or cats are present, and must not rise above 85 °F (29.5 °C) for more than 4 consecutive hours when dogs or cats are present. The preceding requirements are in addition to, not in place of, all other requirements pertaining to climatic conditions in parts 2 and 3 of this chapter. So, my to building with bays have indoor and outdoor access, but no heat, does this mean we are going to have to add a heat source. Our back kennel has access to top half of our sheep barn, we would have to either wall off and insulate the kennel area specifically or insulate and heat the entire barn, the sheep would probably like that....$$$ Quote Link to comment Share on other sites More sharing options...
juliepoudrier Posted June 20, 2012 Report Share Posted June 20, 2012 Just a random selection of the requirements included in the document Eileen linked to: *Animal areas inside of housing facilities must be kept neat and free of clutter, including equipment, furniture, ==Well, it’s my HOUSE, so it’s got furniture and clutter. Oh and is the vacuum cleaner considered equipment? What about some of my dog grooming supplies? There's a cat tree in there too, and sometimes a laundry basket lands on top of one of the crates. Big no-no. But the dogs are crated only when I'm not here, so their ease of spot cleaning probably isn't as important as the ease of spot cleaning, say, my bed.... *The surfaces of housing facilities—including houses, dens, and other furniture-type fixtures and objects within the facility—must be constructed in a manner and made of materials that allow them to be readily cleaned and sanitized ==One could argue that my antiques can’t be readily cleaned (guess Kes better stop sleeping on the Victorian loveseat), or especially, sterilized. But my dogs and cats live in my house. And houses do have items within them that aren't readily sanitized. That could put someone in violation. *Interior surfaces and any surfaces that come in contact with dogs or cats must: (i) Be free of excessive rust that prevents the required cleaning and sanitization ==Some of my Varikennels (in the “dog room,” where there also happens to be furniture) are older and have rusty doors. Oops, violation. *Floors made of dirt, absorbent bedding, sand, gravel, grass, or other similar material must be raked or spot-cleaned with sufficient frequency to ensure all animals the freedom to avoid contact with excreta. (this is in refernce to exercise areas) ==Well my dog yard is also where the chickens free range. I allow the sheep to graze it too. I don’t think I can rake up all the excreta so that no dog ever comes into contact with any. Hmmm…some of my dogs like to *eat* chicken shit. That must be a pretty serious violation. Intimate contact with excreta and all.... *Ventilation must be provided by windows, vents, fans, or air conditioning. Auxiliary ventilation, such as fans, blowers, or air conditioning must be provided when the ambient temperature is 85 °F (29.5 °C) or higher. The relative humidity must be maintained at a level that ensures the health and well-being of the dogs or cats housed therein, in accordance with the directions of the attending veterinarian and generally accepted professional and husbandry practices. ==I don’t run the a/c and the humidity is whatever it is outside. This is North Carolina. I do use fans, so that should be acceptable, but I'm not doG and so can't control the humidity. Sounds like lack of humidity control is a violation? The dogs aren't dead yet, and neither am I. And it was 90 today. And humid. But it could get me in trouble. *(1) The following areas in sheltered housing facilities must be impervious to moisture: (i) Indoor floor areas in contact with the animals; ==What does this mean for indoor dogs housed on carpeted floors? Fortunately I have hardwood. But it's been a while since the floors were refinished, and the floors are, um, 85 years old, so they probably wouldn't pass any test of imperviousness. *(1) The following categories of dogs or cats must not be kept in outdoor facilities, unless that practice is specifically approved by the attending veterinarian: (iii) Sick, infirm, aged or young dogs or cats. ==This could be an issue for anyone raising livestock guardian dogs outside, where pups are often whelped and start their lives living among livestock that they will protect. I wonder if the vet has to approve only once or for every litter? (Note that I agree in general that sick or infirm animals shouldn't be kept outdoors, and yet the kindest thing I did for my LGD with cancer was let her stay where she wanted to be--with her sheep--up until the day I had her PTS. Most certainly a violation, since she was sick and old and infirm. Though any thoughtful person would realize that a dog like her had zero desire to be in my house.) But we're talking about enforcing regulations here, and I doubt it would be easy to get an exception made for cases where it makes sense that the person handled a particular animal in a manner outside of the rules, as in my situation with Maia. And then there was the provision that wire cages in transport vehicles have impervious pans in them. Ranger travels in a crate that's sturdier than the average Midwest wire crate, but it has no pan. Gasp! He has a rubber anti-fatigue mat in there, with holes that would allow any mess he makes to drain onto the floor of my van, but that would be a violation too. So, depending on who's doing the checking and who's doing the interpreting, there's a lot more here than just requiring people traveling with dogs to put them in crates (and making sure those crates have no rust, are properly labeled on multiple sides with "this end up", and not stacked closer than whatever the actual requirement is--don't remember, but it's in there, so you can look it up--and have fans or a/c or heat as appropriate for the outdoor conditions. I suspect one could find plenty of violations of some of those rules at trials, and yet the dogs would still be healthy and happy. I remember the summer my a/c in the van got balky and I had to travel with the windows rolled down. Probably a pretty serious violation. This is a home. It's not a kennel or breeding facility. But if I wanted to breed a litter I'd apparently be in violation of quite a lot of regs. J. Quote Link to comment Share on other sites More sharing options...
Rave Posted June 21, 2012 Report Share Posted June 21, 2012 Just in case it hasn't been posted yet, comments on this proposed law can be posted here: http://www.regulations.gov/#!documentDetail;D=APHIS-2011-0003-0001 Quote Link to comment Share on other sites More sharing options...
Mark Billadeau Posted June 21, 2012 Report Share Posted June 21, 2012 Which of the regulations do you not agree with? 3.2 Indoor housing facilities(d) Interior surfaces. The floors and walls of indoor housing facilities, and any other surfaces in contact with the animals, must be impervious to moisture. The ceilings of indoor housing facilities must be impervious to moisture or be replaceable (e.g., a suspended ceiling with replaceable panels). This means you cannot have carpeting in your house if you are housing your dogs in your house. One could debate if wood flooring meets the impervious to moisture requirement. I doubt our 180 year old heartpine floors would meet this requirement which means our dogs would not be allowed to live in our house. oops, I see Julie has covered these. We also have the temperature issue that Julie has; our house does not have central A/C and we rarely run our window units. One could argue that the temperature requirements do not allow dogs to become acclimated to summer temperatures for working in the heat. The issue here is these regs were written with commercial facilities and high volume breeders in mind. They are not accommodating for dogs bred and raised within someone's home. Quote Link to comment Share on other sites More sharing options...
terrecar Posted June 21, 2012 Report Share Posted June 21, 2012 The issue here is these regs were written with commercial facilities and high volume breeders in mind. They are not accommodating for dogs bred and raised within someone's home. Right, and maybe I'm just not understanding the complexity of drafting these regs, but it seems to me they could cast the net with greater precision. ETA: I thought this was a good response from: a rescue Quote Link to comment Share on other sites More sharing options...
Liz P Posted June 23, 2012 Report Share Posted June 23, 2012 I can't seem to get my comments down to under 2000 characters. It looks like I can upload a longer comment as a letter, right? Quote Link to comment Share on other sites More sharing options...
Alchemist Posted June 26, 2012 Report Share Posted June 26, 2012 I can't seem to get my comments down to under 2000 characters. It looks like I can upload a longer comment as a letter, right? I uploaded mine as a letter when I realized I was exceeding the 2000 character limit. Quote Link to comment Share on other sites More sharing options...
Recommended Posts
Join the conversation
You can post now and register later. If you have an account, sign in now to post with your account.