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MA hates dog rescue
cananian
The headline might be over-the-top, but if they don't want dog rescue to stop in Massachusetts, then they should rescind or modify this "emergency order" ASAP. The emergency order was issued out of the blue without consultation with rescue groups on May 26, 2005 and imposes drastic restrictions on "importing dogs across state lines" which will put out-of-business most rescue groups in Massachusetts by requiring stays in expensive 'state-approved isolation facilities' (only one of which currently exists in MA!) for all imported dogs. Somerville Dog and the Canine Coalition have more information on this surprising and draconian order. It appears that the "National Animal Interest Alliance" is (at least partly) responsible for this undemocratic "order", which was imposed without public consultation or review by appealing to an "emergency" that simply doesn't exist. Poor control of animal health is an issue, to be certain, but the problem is insufficient enforcement resources for the Massachusetts AGR to enforce existing regulations. This new "emergency" adds new regulations which penalize the "good guys" who are trying to monitor their dogs and comply, without addressing the problem of dangerous fly-by-night "adoption" groups at all. If you make it impossible for people to comply with the law, no one will comply with the law. The NAIA seems to be an anti-"animal right" group who is siding with business interests (pet stores and breeders) in trying to stifle competition from rescue groups who save "unwanted" dogs from destruction. It is equivalent to bookstores trying to ban libraries because they suppress the sales of books -- but that's another bee in my bonnet which I'll save for another time.

If you are a Massachusetts resident, contact your state representatives and let them know that rescue groups are an important part of Massachusetts animal welfare. Email me if you'd like more details or pointers on who to write or what to do. Thanks!

I'll post some additional information in the comments to this entry, if you are interested.


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Notes from May 12 MAC meeting (part 1 of 3)

This is part 1 of my notes from a May 12 meeting arranged by the Massachusetts Animal Coalition (MAC) at which Dr. Lorraine O'Conner and Brad Mitchell presented the proposed order. It was emphasized that this meeting was *not* for discussion or feedback, but just to tell us what the order was going to be. Some of the comments are addressed to the folks in Greyhound Welfare who I was representing at the meeting. Additional commentary is on the Canine Coalition's forums.


Massachusetts is planning to pass an 'emergency order' to regulate the import of dogs across state lines. In particular, they plan on imposing a 72-hour isolation period 'in a Department-approved facility' on any dog brought into MA from out-of-state, which would seriously impact most rescue groups in Massachusetts, including ours. Some more details at
http://caninecoalition.com/
The Massachusetts Animal Coalition sponsored a meeting so the rescue groups could hear the story directly from the folks at Massachusetts' Department of Agricultural Resources. Unfortunately, details were rather fuzzy, as "the emergency order was still being worked out". We were told last Thursday that the order would be released "tomorrow or very early next week", and that we'd get exact details from the order at that point.

I got the distinct feeling that the order was 'supposed' to have been released already by the time of the meeting, so that we could have been asking more direct questions about its language; but since it wasn't done yet we were reduced to asking about generalities and getting vague answers in return. When the order is released, it will appear in the 'News and Features' section of

http://mass.gov/agr/
And we were told we could call [REDACTED: email me for this phone #] to ask any questions we had about it. Esther Wegman would probably be the person we'd talk to at that number, but "she may not know anything immediately" (has to check with Brad Mitchell and Dr. Lorraine O'Connor, who need to coordinate among themselves) but that "she *will* get back to you".

They said there were 3 things which they "couldn't allow to continue":

  1. Dogs coming into MA with improper health certificates (ie, certs which say the dogs aren't healthy, or have "wounds of unknown origin", or who are being treated (but not yet cured) of a communicable disease at the time they are shipped (with other dogs) to MA.) Health certificates need to have an actual address (ie not a PO box) of the actual destination of the dog, so that it can be tracked down if necessary (ie, just city/state is not enough).
  2. Inadequate record keeping. If there is an outbreak of disease, they need to know where the dogs came from and where they went. They were also upset at the lack of identifiability of most dogs imported into MA, who have descriptions like, "Sheltie mix, brown." They prefer microchips or tattoos. [This might be relevant for 'obscured tattoo' greyhounds.]
  3. Dogs being imported and placed directly in people's homes w/o an isolation period (72 hours, in this case). They are worried that dogs who are exposed to ill dogs in the truck to MA and made sick are put in situations where the disease would spread out of control to a very large population of dogs.

Notes from May 12 MAC meeting (part 2 of 3)

Second part of my notes, split for size reasons

They said they are taking 'two steps' to remedy these faults:

  1. An "emergency order" being released "tomorrow to early next week". This will consist of "interim guidelines" and will take effect immediately. Anyone who houses, rooms, etc dogs will have to register, on a "page-long form" which will be made available on the web. Those with an existing isolation facility will be given 90 days from the posting of the order to get their facility inspected and approved. Those without an existing facility (whose dogs go directly from a transport to an adopter/foster) will be given 10 days to get animals "already in transit, through the system" (ie, transported into MA). Then they will have to completely stop importing dogs until they can get an isolation facility. There may need to be "notification and guidelines for animals still in foster homes" after the 10 days, although details here were extremely fuzzy. "We'll work something out."

    The "interim guidelines" in the emergency order can be changed easily with no notice, so there may be some flexibility if they need tweaks.

    The registration will be online and no-cost. Only the rescue needs to register (not all the fosters), but the rescue need to keep an accurate list of all the people involved. You also need to keep track if someone in your group is also fostering for groups other than yours, so that if there is a problem with the other groups' dogs, your dogs can be checked as well.

  2. After the 'emergency order', they will be working on a "legislative or regulatory fix". This needs to go through a public process with hearings, etc, and will take time. These regulations will attempt to formally differentiate 'pet shop', 'shelter', and 'foster home'.

Notes from May 12 MAC meeting (part 3 of 3)

Third part of my notes, split for size reasons
Other notes:
ISOLATION:
exact requirements will be in the (not-yet-published) order, but the basic idea is "a place that can be cleaned and disinfected, with good ventilation and lighting. Isolated from other animals" although it's possible that the isolated animals can be in one section of the room/kennel; maybe not necessarily a whole separate isolation room. "Cleaned and disinfected" means tile that can be bleached, probably with its own sink. "A minimal period of isolation from the general population." It was asked: "can we isolate in a foster home?" Answer: "We are not comfortable with the residential setting." Possibly in a separate garage or barn, but not in the basement. Not convinced that would sufficiently isolate from other animals and people in the foster home. Also, "if the dog is sick and throws up on the rug, are you going to rip up the rug?"

"Do you realize the isolation requirement will kill most rescue groups?" Answer: "Yes." They "hope" that rescue groups will form associations with veterinary hospitals or other groups to share isolation facilities.

In response to my question about possibly locating an isolation facility at Chris' kennel in Seabrook: "May have some flexibility with respect to state lines". May be able to inspect isolation facility in NH. Brad Mitchell seems to backpedal on this when I asked him again about this after the meeting.

Also, "single dog transport might be different". They're more worried about trucks full of dogs spreading disease. Also "surrender from a known (residential) source in contiguous states" might be different. And "less risky if not from a kennel situation".

MA has only have one known isolation facility at this time.

Also, wording is "accredited vet," not just licensed, for pre-transport health certificate (and post-isolation exam, presumably). "Official health certificates" are necessary for out-of-state dogs, not just a letter on vet letterhead. State of origin is required to forward a copy to the state of destination. For fractures or non-contagious disease, a statement on the certificate that the animal is "safe to transport" will be required.

There are formal specifications for an acceptable isolation facility in the 'pet shop' guidelines at:
http://www.mass.gov/agr/animalhealth/petshops/330%20CMR%2012.00%20Final%20no%20red%20line.pdf
They "will not hold you to the letter of the law" here; they "recognize that rescue groups are not pet shops". But "they *are* good guidelines" for what your isolation facility should be like.

A 72-hour period in a vet facility (ie, during the spay/neuter) may count as isolation. Later they said, "a vet office can be used for isolation" but they still wanted to see a separate room and a separate sink. ("Want" may not be the same as "need" in this case.) Some rescues who get their dogs transported before spay/neuter hoped they could see a glimmer at the end of the tunnel here: perhaps they might be able to do isolation at the same time as spay/neuter and not have the additional cost be prohibitive.

Finally, Brad Mitchell from the MA Department of Agricultural Resources suggested that [Greyhound Welfare] talk to Pat Cabral of the MA Greyhound Care and Adoption Council. There might be grant money available to underwrite isolation:

http://mass.gov/agr/greyhound/greyhound_grants.htm
although this seems to heavily favor groups that adopt from MA tracks. [Greyhound Welfare adopts mostly from a track in Seabrook, NH.] He indicated that, even in the absence of grants, Pat would be a good person to talk to about greyhound-specific issues relating to the emergency order, and that she might be a "point person" for getting waivers recognizing the special situation our greyhounds come from (ie, much better health monitoring on the source end, etc).

Who supports Animal Shelter Reporting?

MASSFED, the Massachusetts Federation of Dog Clubs and Responsible Dog Owners, supports House Bill #3650, Animal Shelter Reporting, introduced by Representative Kay Khan, on the grounds that "although pet stores are highly regulated, there is currently no regulation of 501(C) 3 private humane shelters that operate as de facto pet stores."

At the same time MASSFED opposes H1346, Commercial Breeders, introduced by Representative Paul Kujawski, on the grounds that "People with no profit motivation who breed dogs and cats as a hobby would be labeled as commercial."

How come what's good for animals in the care of rescue organizations and shelters is not good for animals in the care of hobby breeders?

The shoe has dropped

Today I learned that Greyhound Friends was ordered to surrender their dogs after being found in violation of this "emergency order". According to the law (as best I can read it) violations are punishable by fines of up to $500/dog/day.

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