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DogFederationofNewYork.org
P O Box 547, Rhinebeck, NY 12572DogFedNY@aol.com
Dog Federation of New York
OCTOBER, 2009 PAGE 1
Albany: Ag & Mkts hosts “Pet Dealer Focus Group” meetings
On Wednesday, Oct. 21 the first in a projected series of meetings took place in Albany under the auspices of theNYS Department of Agriculture and Markets. DFNY wasinvited to attend, and following are highlights of the 2hour meeting.Also present were representatives from NY Houndsmen,Assoc. Dog Clubs of NY, ASPCA, NYS Humane Assoc.,Mohawk Hudson Humane Society, PIJAC, NY FarmBureau, NY Masters of Fox Hounds, HSUS, and the NYSVet. Medicine Assoc.
Background information
The meeting began with a review of the current petdealer regulations, which went into effect in 2000. TheDepartment noted that at the time the pet dealer programwas enacted, $7 - 800,000 was the estimated cost for administering the program, but that in reality the programreceives $2 - 300,000 annually for enforcement.The $100/year that each pet dealer pays in licensing feesis no where near adequate to fund the program, yet Gov.Paterson wants the program to be self-sufficient.Ag & Mkts spokespeople explained that the programemploys 20 inspectors. They are licensed veterinarytechnicians supervised by veterinarians working for Ag &Mkts. The inspectors are assigned regionally throughoutNY, inspections are done upon application for a petdealer license, and annually thereafter. "Specialinspections" are done on complaint.For 2009 YTD there have been 360 inspections. Of these, 85 were triggered by complaints, 154 were re-inspections and 43 were new applicants.Inspectors note "general deficiencies" which are not life-threatening (generally, sanitation issues), and give thepet dealer 30 days to correct the problem. Inspectorsalso note "critical deficiencies" which
Dog-friendly, dog-safecommunities for all New Yorkers
threaten health and safety, and give pet dealersfive days to correct them.Pet dealers are then re-inspected after 30 (or five)days to make sure that the problems have beenaddressed.
Ag & Mkts’ primary concern
.The Department's biggest issue is that it is difficultto document the number of animals an individualsells or offers for sale. Current NYS law defines“pet dealers” by the number of animals they sell or offer for sale and Ag and Mkts monitors websitesand publications for advertisements.Because people selling puppies no longer advertise a specific number of dogs for sale, theDepartment believes that individuals andenterprises that should be licensed and regulatedas pet dealers are falling through the cracks.
DogFederationofNewYork.org
P O Box 547, Rhinebeck, NY 12572DogFedNY@aol.com
Dog Federation of New York
OCTOBER 2009 PAGE 2
As a remedy, the Department would like all petdealers to be required to authorize their vets torelease veterinary records on all animals for sale so that the Department can verify that aspecific
animal
is under a vet's care andreceiving appropriate treatment.
Lack of socialization and exercise
Current regulations require that dogs' primaryenclosure allow the animals to fully extend limbsand turn around. The Department wants theminimum amount of space provided to each dogdoubled -- so that crates would need to be twiceas long as the dog measures (nose to tail).
Need for “stop sale orders”
License revocation is a lengthy process and inthe meantime a pet dealer may continue to sellanimals. The Department wants to be able tostop sales of pets pending license revocationproceedings.
Changes to "pet dealer" definition
Because Ag & Mkts finds it difficult to determine thenumber of dogs sold or offered for sale, theDepartment wants the number of breeding (intact)
females to determine whether an individual or enterprise qualifies as a pet dealer.Using the USDA guidelines as a model, theDepartment proposes more than 3 intact females, or selling or offering for sale more than 13 dogsannually, as a threshold.
Additional comment
Ag & Mkts identifies dog licensing data -- including"purebred” license records -- as a tool to identify theowners of intact dogs.
(continues from page one)
Ag and Mkt spokespeople then describedseveral additional concerns within theDepartment:
Sick animals may be treated withoutveterinary supervision
Currently, if a sick or injured dog is identifiedduring inspection, the pet dealer is required toobtain veterinary care for the animal. TheDepartment finds, however, that upon re-inspection the pet dealer may provide (for example) a bottle of antibiotics as evidence of appropriate care for the injured/sick animal, butthey are not required to document that theanimal actually saw a vet or that the antibioticwas prescribed by a vet for that particular illnessor injury.
DFNY believes that it is inappropriate and counterproductive to require home, hobby, and sports dog breeders to comply with regulationsmodeled on USDA commercial licensing standards.
Puppies! What would the world be without them?
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Dog Federation of New York
OCTOBER 2009 PAGE 3
Dog Federation of NY expresses deepconcern
Inappropriate standards
While DFNY wholeheartedly supports and commendsthe NYS Department of Agriculture and Market’scommitment to the health and welfare of animals, andappreciates the opportunity to discuss these items withDepartment spokespeople, we believe that it isinappropriate and counterproductive to require home,hobby, and sports dog breeders to comply withregulations modeled on USDA commercial licensestandards.For example, guidelines for pet dealer standards of carenow circulated by Ag and Mkts require animals to behoused in “primary enclosures or cages.” The “primaryenclosure” surfaces—presumably the floors, ceilingsand walls of a room or rooms if a dog is living in a homeas a family member—must be “impervious.” Guidelinesrequire surfaces that are “non-porous, durable andeasy to maintain. . .Surfaces must withstand scrubbingwith detergents and disinfectants. . .[and] withstand theimpact of water under pressure, if necessary.”Clearly, these guidelines and underlying law were notwritten for raising dogs in a home environment.
Current legislation
Ag and Mkts advises that no legislativeproposal has yet been drafted in response to their concerns, yet DFNY identifies components of severalexisting bills now before the state legislature that areconsistent with the Department’s recommendations.For example, under proposed NY A7983/S4961(Paulin/Oppenheimer) pet dealers include anyone withcustody of
more than four intact female dogs
over theage of six months.Additionally, under the Paulin/Oppenheimer proposal pet dealers are
required to authorize theblanket release of all veterinary records
for allanimals in their care to the Department or itsauthorized agents as well as comply with a host of new requirements and regulations.
Keeping New York dog-friendly and dog-safe
We believe that locally bred, locally raised dogs arean excellent choice for New Yorkers who would liketo acquire a pet or working companion, and we aredeeply concerned by legislation that curtails or prohibits lawful, humane breeding and animalhusbandry practices.DFNY looks forward to collaborating with the NYSDepartment of Agriculture and Markets and other caring, responsible dog owners to find workable,reasonable solutions to the concerns we all share.
Help DFNY help you
The Dog Federation of New York welcomesindividual dog owners and dog-related clubs andorganizations. A New York State not-for-profit, weare the only organization focused on laws and legalissues impacting responsible New York dog owners,and we advocate for strong, humane legislation.Visit our website, download an application, and joinus today!
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