Urgent: Your Help Is Needed!

Cross posted with permission from Joan Capaiu Greene:

“[Note: this information applies equally to service animals other than canines.]

Many disabled individuals who use assistance animals – most, in fact – train their own service dogs. Thousands of others buy or are given pre-trained service dogs by organizations or individuals. Most of those animals live in the trainer’s home while learning their assistance skills. If the USDA’s proposed changes to the AWA are adopted, this will change.

In practical terms: the cost of providing pre-trained SDs to the disabled will increase by hundreds of dollars per animal. Either the disabled handler, the trainer, a 501c3 charity or some kind-hearted soul will have to pay the costs for each new handler to travel to see their next SD before it comes home with him/her.

The consequences for a trainer’s failure to follow these rules, and a new SD partner’s failure to visit the dog *before* bringing him or her back home: the trainer *will* be classified as a commercial USDA wholesaler and be subject to onsite USDA inspections. Forever after.

Here’s what those trainers will have to do to be in legal compliance:

http://www.aphis.usda.gov/publications/animal_welfare/content/printable_version/fs_compliance_inspection.pdf

In a nutshell:

– if a service dog trainer delivers a trained animal to a disabled individual, and

– if that disabled individual did not first visit with that specific dog in the trainer’s home,

then: the trainer will no longer be able to legally train SDs in their home. All their future service dog trainees will, legally, have to live in USDA-approved facilities.

Even if the handler and trainer have known each other for decades, even if this is the second or third SD trained by the trainer for the disabled handler, even if it is very difficult for the disabled handler to travel .. this will be the ‘new normal’ for obtaining a trained service animal. The USDA doesn’t care.

This law may never touch you personally, and you may become a fantastic owner-trainer for your next SD as a consequence. 😉 But: think about those who physically, mentally or emotionally *cannot* train their own service animal. What about them? I *do not* recommend ignoring this dangerous proposal or telling people, “they’ll never catch me; they’ll never know; they’ll never find out.” That is foolish beyond words.

~~~~~~

Please go comment at the portal site and ask every person you know to do so as well. Write snail mail letters too – they will be even more valuable to the USDA. Submit comments online here:

http://www.regulations.gov/#!documentDetail;D=APHIS-2011-0003-0001

Read already-posted comments here:

http://www.regulations.gov/#!docketDetail;dct=FR%252BPR%252BN%252BO%252BSR%252BPS;rpp=10;po=0;D=APHIS-2011-0003

Find – and write – your Congressional representatives online here:

http://www.congress.org/news/ 

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6 thoughts on “Urgent: Your Help Is Needed!

  1. Almost all handlers go to the trainer or program to learn to use their new dog, regardless of having an SD/having SDs in the past (each dog is different to work with, plus a person’s needs may change so new tasks may be needed), for one to three weeks prior to bringing the dog home with them. This is called “team training”. Some handlers have gotten with the dog at times before those weeks (especially in the cases of alert dogs) or have helped the trainer train the dog. Then there are the scumbags who scam ppl out of their money by promising to deliver an SD to them and they either never deliver a dog or the poor dog they do deliver has been living in terrible conditions and isn’t trained at all.

    This is the first I’ve heard about this proposed law, but it sounds like it is to protect the consumers. Most trainers and programs wouldn’t be affected. Travel expenses for those who can’t afford to pay are fund-raised by the handler (or an organization such as the Lions Club via the handler) or program or both, as are any other expenses such as a fee for the dog/equipment, and some trainers and programs offer housing to the handlers during the team training weeks.

    While I don’t think this is a bad law, I also don’t think it is necessary.

  2. …And after reading a good part of the actual proposed law, I see this talks about animals for use as PETS (SDs are not pets) and it is for the sellers of the actual animals, not the trainers of them. Selling the service of training is not the same as selling a dog. This proposed law is to prevent puppy mills, not to prevent service dog training.

    • Watch out for such a rigid classification as “pets”, it will bite you. How do you know which pups in a litter will be working dogs and which will be “pets”? If you know that, wow, you know something. This is another stealth move by HSUS to chip away at our rights to own, breed and train our animals. If a trainer isn’t the breeder, good luck with finding a legal source for new dogs if this rule happens. USDA licensed breeders MUST purchase all of their breeding stock from other USDA licensed breeders, and there is no consideration given for working ability, a pedigree, healthy lines, long-lived lines, nothing but the breed is even involved. Quality is not going to be available, let alone any guarantees of working ability in an entire litter.

      There really is no such thing as a legally defined “puppy mill”, it is a slur word designed by PeTA and the animal rights movement. It has nothing to do with size or numbers, because the New Hampshire HSUS director has announced the addition of the term “mini-mills” to cover ALL breeding. They allow for no distinction whatsoever between reputable quality dog breeders and so-called “puppy mills”. I wish people would stop using that term, it only gives unwarranted credibility to animal extremist groups.

      And yes, I’m afraid this under handed attack on purebred dog breeders WILL prevent service dog training, they just don’t have to say it, it will happen as a result of the drastic reduction of quality breeders. Substandard breeders who aren’t currently licensed anyway will not be motivated by this garbage to get licensed. It won’t happen. Good people will be shut down, and the bad actors will thrive, along with the underground suppliers of dogs that match no breed standard, have no traceable pedigree, are not health tested, unsocialized buckets of nerves, weak minds training . ..

  3. I know many people might not see the terrible ‘wrongness’ of this rule change, but it really is a terrible thing. There is an important class of dog breeders who will be forced out of breeding by this rule – the Home Based dog breeders who show their dogs, breed rarely, and breed to show. The vast majority of these breeders are responsible for the best quality pets available to the public – at least the public who know how to find them. There are regulated in most states, under LOCAL control and standards,which are more appropriate than USDA kennel standards, which are designed exclusively for large scale breeding operations and laboratories where animals are housed. The dog fancy breeders, stewards of their respective breeds, who belong to kennel clubs, parent breed clubs, support local animal shelters, volunteer in their communities, participate in and fund RESCUE, contribute research and big money to the AKC Canine Health Foundation which benefits ALL dogs as well as humans who suffer from some of the same health issues that dogs do – this is NOT anything like a typical USDA-style for profit “business”. There are many thousands of these people, although the number of dogs they produce will not come close to that produced by large commercial facilities. These dogs are almost always born and reared in a home environment, which is arguably the best way to raise pets that will live in that same kind of environment.There is no way that a private home can qualify for a USDA license, even if it were appropriate, which it ISN’T. Before you glance at the summary written by USDA/APHIS (and HSUS, who aims to destroy the purebred dog fancy) READ the darned thing, and you will see that. Read what is necessary to pass a USDA inspection, and it will be clear that the typical laundry room or breakfast room location for a whelping pen, and the typical back yard as a puppy ‘run’ will never work for this license.

    This rule change will, if enacted, eventually wipe out dog shows, the wildly popular dog sports like agility, will stop hunt tests and retriever trials.

    And it WILL severely limit the breeding of dogs for service dogs, search and rescue dogs, Therapy dogs. It won’t take long at all to wipe out several unique dog breeds in the country. I know this because my favorite breed is rare, classified as endangered by the AKC, and without internet sales of our dogs there will be no more, period. Could take only a few years for this to happen with this rule in place. Some breeds even faster, like Otterhounds, Clumber spaniels, American Foxhounds, Irish terriers, with teeny tiny populations and not enough litters born NOW to keep even.

    Here’s why – a USDA-licensed dog breeder MUST purchase all of their dogs from another USDA-licensed breeder, no exceptions. I co-own two intact females of a rare breed with their breeder, and between us we “own” more than 4 “breedable” females. They aren’t going to be bred, and we see no good reason to spay them. Remember as well, this rule includes any species of “pet” animals in the count of “breedable” females, so if someone has two retired bitches, plus a couple who are sexually mature but too young to make a final decision yet on whether to breed or not, and an intact female CAT, plus the kids’ female rabbit which they are keeping for a 4-H project, well, there you have it, you must apply for a USDA license – which you will not qualify for in a home environment.

    Is it making sense now how sneaky and stealthy this plan (by HSUS) is, and how easy it will be to collapse a wonderful way of life in America because some tiny minority of our people believe in veganism and feel compelled to force the rest of us to live the way they want us to.

    Sorry this is so long, but when I saw a couple of comments from people who feel that there might be some good in this rule change, I just had to speak out. I am not a breeder, but this year my girls’ breeder would like my 3 year old to have a litter, as she has what the breeder wants to keep in her line, and grow. This rule change will stop us from doing that, because we know for sure that at least two guaranteed homes for puppies are more than 1,000 miles away, and we originally planned to meet at a dog show half way with their new pups. Do we renege on an agreement, or just not breed, hard decision.

    And completely UNNECESSARY!

  4. Pingback: On behalf of all US dogs, I need your help! - Poodle Forum - Standard Poodle, Toy Poodle, Miniature Poodle Forum ALL Poodle owners too!

  5. These proposed laws do not take into account how MANY single trainer and smaller organization service dog programs work. I don’t train one dog for a person. I often have several in training that ‘might’ work. I won’t know which dog I’m going to place with the individual until team training – which may be held in my location or the disabled handler’s location. I use psychological profiling, as well as observations made during team training, to make an appropriate match. So tell me – how am I suppose to know which dog is going to be placed in advance to have them meet the dog prior? And for those trainer’s, like myself, who willingly travel to the client, rather then have them travel to us for team training and placement? What are we to do? Some of these handlers CAN NOT travel. PERIOD. And I RARELY have team training in my home. That would be unprofessional. I often rent or have loaned to me space, do it in a hotel room or conference room, etc. The client is NOT choosing the dog – I am choosing the dog for him. I have the experience to match a team – the client will pick whatever dog most closely matches their preconceived notions of what a service dog is — which may or may not be the right dog.

    The same could be said for ethical breeders. MANY ethical breeders don’t allow the puppy buyer to choose their pup. They take the client’s history and situation under advisement, their future goals and plans into consideration, and choose the pup that is the best match. RARELY in these situations does the puppy buyer come see the pups. The pup is often hand delivered with someone flying him. These breeders are doing what’s best for their dogs. They know the pups better then the client.

    I can see what this law is trying to stop – puppy mills who practice mail order sales. But this isn’t taking into consideration how the rest of the ethical dog world functions.

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