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APHISRulemakingAPHIS-2006-0024

Minimum Age Requirements for the Transport of Animals

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Animal Welfare Institute filed 1 comment on this docket between Jul 8, 2008 and Jul 8, 2008. 38 other organizations filed here. The comment window closed 6538d ago.

What Animal Welfare Institute filed (1)

Jul 8, 2008· Comment from Cathy Liss, Animal Welfare Institute· APHIS-2006-0024-0203

July 8, 2008 RE: Docket No. APHIS-2006-0024 To Whom It May Concern: The Animal Welfare Institute welcomes APHIS's recognition of the need to amend the Animal Welfare Act regulations to include minimum age requirements for commercial transport for all other covered species besides dogs and cats. We agree completely with APHIS's position that "all animals should be afforded the same protections as provided for dogs and cats" and that the new rule should "protect those not yet safeguarded from possible stress, distress, pain, suffering and/or death during the transport process." The proposed rule published in the Federal Register on May 9, 2008, Docket No. APHIS- 2006-0024, is a good first effort, but it is insufficient. The species that will be covered by the new rule are too varied to allow for a "one size fits all" standard. For some species, such as elephants and nonhuman primates, nursing may continue for months or years, and the young depend on their mothers or other adults for long periods of time while they acquire their "social skills." As the proposal itself recognizes, "the young of social species need physical and social interactions for proper development, and a loss of role models and companionship from an animal of the same species can lead to a lifetime of behavioral and social problems." Consequently, transport in commerce (for other than medical emergencies) should not be allowed during this period of ongoing dependence. Moreover, one must question the appropriateness of an exception to a "minimum age for commercial transport" rule to allow for the shipment of any species to a registered research facility. Even the International Air Transport Association, in Chapter 12, "Life Sciences Logistics for Laboratory Animals," of its publication Live Animals Regulations, states the following: Animals that have not been weaned often have difficulty in regulating body temperature and may be ill-prepared to adapt to normal variations in temperatures that can occur during shipping. Depending upon age, they may be incapable of eating solid food or may be unable to access water sources within the container. This suggests an unacceptably high risk to the unweaned animals, which is not outweighed by the fact that they are going to research institutions. It is not the function of the Animal Welfare Act to help researchers acquire unweaned animals at the expense of the animals' welfare. Therefore, we recommend that there be no exception to the rule for shipments of any animals that are under eight weeks of age and/or are unweaned. We appreciate APHIS's effort to address this flaw in the Act's regulations that has denied to all covered species the protections afforded to dogs and cats of a minimum age requirement for commercial transport. We respectfully suggest, however, that the proposed rule as published does not provide sufficient protections for those species whose dependence on one or both parents or other adults of their species extends beyond weaning and/or eight weeks of age, and it endangers the welfare of animals being used in research to allow them to be shipped before they are weaned or meet the minimum age requirement. We ask that APHIS republish the proposed new rule after it has been revised to address these concerns.

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Abstract

We propose to amend the Animal Welfare Act regulations by adding minimum age requirements for the transport in commerce of exotic and wild animals. The regulations currently contain such requirements for dogs and cats, but no corresponding ones for exotic and wild animals, despite the risks associated with the early transport of these species. We also propose to amend the regulations to allow, provided certain conditions are met, for animals to be transported without their mothers for medical treatment and for scientific research before reaching the minimum age and weaning requirement. Establishing minimum age requirements for the transport of exotic and wild animals and providing for the transport of animals that have not met the minimum age requirements are necessary to help ensure the humane treatment of these animals.

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