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My Letter with commentary on new commercial dog breeder rules

Following is the letter I sent to Drs. Woods and Hickam.

Subject: Commentary on proposed commercial dog breeding regulations

Dear Doctor Woods and Hickam:

I appreciate this opportunity to provide commentary on the proposed new rules to be added to the Animal Care Facilities Act (related to Senate Bill 161.1). Following are my requested clarifications and modifications for these rules.

1. In the section defining “Necessary veterinary care”, please provide further clarification that the once a year examination be a hands-on physical examination, and not a visual inspection. A visual inspection is not sufficient in order to determine the dog’s health.

2. In addition to the inspection, please provide some form of clarification about what a “serious illness or injury” is. I believe that we’ll find that a non-breeder’s idea of “serious illness and injury” differs significantly from a breeder’s. The rules are far too vague in this regard.

3. You provide a definition for Pet, and limit it to dogs, but ACFA applies to dogs and cats. How will you reconcile this seeming conflict?

4. I find it disconcerting that you would charge the same fee to a non-profit shelter that you charge a for profit commercial breeder. Though you don’t have as much discretion about charging the fee, due to a law passed as an amendment to another law last year, you do have some discretion about how the fee is calculated. I hope that you consider formulating an algorithm that doesn’t harm legitimate nonprofit shelters and rescue organizations, or, at a minimum, provide for an exemption.

5. The new rules should ensure that existing wire floors grandfathered in should still be sufficient to prevent dogs paws from falling through holes, or dog claws from being caught, and the dogs getting injured.

Again, I appreciate this opportunity to provide commentary on the proposed rules.

Sincerely,

Shelley Powers

See? I can be polite when so moved.

I also cc’d the letter to Jon Hagler, Director of the MDA.

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Breeders Pressuring Missouri Dept of Agriculture into weakening “The Solution”

updated

This is an alert that was put out by the Missouri Alliance for Animal Legislation (MAAL) and the Humane Society of Missouri. We’ll get into “I told you so”s at some later time. Right now, we all have to pull together to prevent this abominable action.

One of the regulations agreed to with the “Missouri Solution” was that each dog at a breeder must be physically examined annually by a veterinarian. The Proposition B rules that would have required that injuries and illnesses be treated by a veterinarian were removed, but at least this one minimal requirement was left.

The dog breeders agreed to this. Their representatives signed on to this.

Now, they’ve changed their mind. They’re pressuring the Missouri Department of Agriculture to drop this requirement and return it to the much weaker “visual inspection” that we had before Proposition B or the Missouri Solution. This means that all a vet needs to do is visit the breeder, have a cup of coffee, maybe glance into the cages (if the dogs are lucky), and then be on his or her merry way.

After all, it costs so much money to actually physically care for the dogs.

The commercial dog breeders are now trying to pressure the Missouri Department of Agriculture to weaken this provision to require only a “visual inspection” of the dogs rather than a complete hands-on physical examination. Many breeders are even insisting that the dogs do not need to be removed from their cages for this required annual examination. Predictably, one of their main concerns appears to be the added expense of a hands-on exam vs. a visual inspection of their dogs.

This is what comes from expecting honorable behavior from dishonorable people. However, for Nixon and Hagler to even contemplate this weakening of a law they touted as a “wonderful compromise” just a few short months ago…well, so much for respecting the voters of the state of Missouri.

Right now, you need to send a letter. No, not an email. No, not a phone call—a letter.

You need to send a letter expressing your outrage of this underhanded move. However, don’t write like I do at this site. HSMO and MAAL are asking that you be “polite”. So be polite. Feel free to bitch on Facebook, Twitter, or Google+, but be polite in the letter.

The “official comment period”, which the Department of Agriculture didn’t deign to let the public know about, ends September 30th, so you need to hustle. You can express your opinion of this move, as well as provide other comments on the new rules.

Send letters to both Jon Hagler, Director of the Department of Agriculture, and Dr. Taylor Woods, State veterinarian. The addresses are:

Dr. Taylor H. Woods (now Dr. Linda Hickam)
State Veterinarian
PO Box 630
Jefferson City, MO 65102-0630

Dr. Jon Hagler
Director of Agriculture
Missouri Department of Agriculture
1616 Missouri Blvd.
Jefferson City, MO 65102

The only required letter is to the State Veterinarian, but I’d send a letter to both.

If you want me to publish your letter, please email me a copy.

Please also email all your Missouri friends and family, and ask them to write a letter, too.

The dogs need us.

updated

A new State Veterinarian has just been chosen: Linda Hickam. Address your letter to her directly.

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No, I don’t want to buy that puppy

A poem has been appearing on several puppy rescue and shelter sites and Facebook pages. According to one site, the poem was a “letter to a roadside vendor by Harriet Rankin”.

No, I don’t want to buy that puppy.
I am a rescuer.
I’ll see him later.

After the fool you sold him to realizes how much work a puppy is.

After he digs out of the boring backyard he was banished to, for the heinous crime of being untrained.

After he roams blistering hot streets, hungry and lonely and confused.

After he picks up parasites and loses weight from throwing up garbage that he eats.

After he gets bitten for wandering into the wrong dog’s territory (and it gets infected).

After a car clips him and breaks his leg, adding pain to the thirst, hunger and loneliness.

Then I’ll find him.

I’ll pay five times what you were asking for him to get him cleaned up and vetted.
I’ll spend fifty times the hours you spent with him, teaching him what he needs to know.
I’ll take a hundred times as long as you did to find him a forever home that loves him.

So no, I don’t want to buy your puppy.
I don’t have to.
He’ll be mine soon enough anyway.

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Critters

Rabbit Ridge: Recent Missouri Department of Agriculture Inspections

I just received the recent inspections for Rabbit Ridge from the Missouri Department of Agriculture. This joins with the recent USDA inspections.

As you can see, the MDA has had to do three inspections since April. The MDA also found problems at Rabbit Ridge—some very significant, such as dog with mats, hair loss, and wounds on his feet.

I still don’t have the August 2nd inspection from the USDA. In fact, the USDA pulled the August 15/16 inspections from the APHIS database, though I have a copy linked in my Sept 3 Rabbit Ridge writing.

One thing I like about the MDA reports: they provide the count of adult dogs and puppies. According to the inspection in June, Schrage has 204 adult dogs, 72 puppies, for a total of 276 dogs.

I also estimate that this one breeder has had to be inspected over 10 times so far this year, and there’s still 3 1/2 months more to go in 2011.

State Senator Munzlinger once responded to someone in his district who questioned him on Rabbit Ridge, “I find it disconcerting that some people are willing to ruin the reputation of a licensed breeder in good standing based on personal agendas and rumors.”

You can’t ruin what’s already crap, Senator.

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Rabbit Ridge: Same Old Bad Tricks

Updated

It’s been some time since we checked into our first Kennel Campaign kennel, Rabbit Ridge. Too long, it seems.

An August 4th inspection in the USDA APHIS database provides the following rather alarming information (complete inspection report):

There is a hutch style enclosure on the east side of the facility that did not have sufficient shade provided during the day light hours. The location of the enclosure is such that during the late afternoon and early evening hours there is no shade provided for the dog. Dogs that do not have sufficient shade could suffer from heat stress. Dogs must be provided with sufficient shade during the daylight hours for their health and well being at all times.
Licensee fixed at time of inspection.
This is a repeat non compliant item.

This is a focused inspection specifically addressing the Direct non compliant items related to severe heat conditions found during inspections on 2 Aug 2011.
2.40.b 2 – Adequate Veterinary Care – All of the puppies identified during the inspections appear normal. The 15 puppies identified during the focused inspection on 2 Aug 2011 were examined by a veterinarian.

3.2 a – Heating, cooling, and temperature – Two window unit air conditioners were added to the facility for cooling. The temperature at the time of inspection was 83.2 degrees F inside the facility.

3.3 a – Heating, cooling, and temperature – A window unit air condition was added to the facility for cooling. The temperature at the time of inspection was 81.6 degrees F inside of the facility.

Unfortunately, the USDA is not providing a copy of the August 2nd inspection in the APHIS database. I’ve since submitted a FOIA request for this inspection, as well as a Sunshine Law request to the Missouri Department of Agriculture for any recent inspections.

What this inspection does tell us is that there were one or more buildings at Rabbit Ridge that had missing or inadequate cooling on August 2nd. If you’re not familiar with what our weather has been like this summer, on August 2nd, Columbia, Missouri set a record high of 108 degrees F that day. The archived weather forecast for Edina on that day is:

Tue, Aug 2

Day… Very hot and humid. Mostly sunny. High around 101. Highest heat index readings of around 115 in the afternoon. Southwest wind 10 to 15 mph. Overnight: Partly cloudy with a 30 percent chance of showers and thunderstorms. Low in the mid 70s. Highest heat index readings of around 111 early in the evening. Southwest wind around 10 mph in the evening becoming light after midnight.

Anyone with any decency would know that in weather like this, you have to provide additional cooling for dogs. You either have to bring them into your home or provide some form of air conditioning. At a minimum, you have to provide shade.

It doesn’t matter that Schrage “fixes” things when he gets busted for violations of MDA and USDA animal welfare laws. What does matter is that Schrage’s history is a pattern of gross animal neglect, corrected only when ordered to do so by USDA or MDA inspectors.

August 2nd…this followed one of the hottest months of July on record. How much did the dogs suffer at Rabbit Ridge before the USDA inspection that forced Schrage to put in window air conditioners? How much did that dog who didn’t have shade suffer?

How many dogs died from heat that we don’t even know about?

Attorney General Koster has been spending considerable time bragging about how things are better for the dogs in Missouri since the new law was put in place to override Proposition B. He’s even created a little web page to this effect. So let’s ask him about Donald Schrage and Rabbit Ridge, and the man’s continuous and re-occurring violations. Let’s ask Koster a question: at what point do we stop holding Schrage’s hand; stop doing inspections every few months because that’s the only way to ensure the animals are given minimal care?

Let’s ask Director Jon Hagler of the Missouri Department of Agriculture how much does it cost the state of Missouri to keep Schrage in business? How many times do we have to re-inspect this man because he always, always has new violations? Consistently, year after year, violation after violation?

And where was the MDA when these dogs were suffering in July?

Bob Baker of MAAL has been talking about how much better things are now with the new Missouri “solution”. Are things better? Because I don’t see that things are better. Busting exactly one breeder a month is not “better”.

Dogs without protection from heat in one of the hottest Missouri summers in record is not “better”.

As soon as I get the requested inspections, I’ll post an update.

Updated

APHIS loaded another inspection, but this one is dated August 15th, and is a focused inspection.

Among the problems:

A male Cocker Spaniel with yellow discharge covering both eyes.

A female American Eskimo with dark brown discharge coming from her vulva.

A male Shih Tzu with skin lesions, scabs, and sores.

Two female American Eskimo dogs put in with two larger American Eskimo dogs suffered from bite wounds. “They’ve been fighting since I put them back”, was Schrage’s comment.

These are all repeat violations. Repeat violations.

There were several dogs from the August 2nd inspection, which I still can’t access, that were treated by the vet. Several more not, though.

A male Shih Tzu and a Cocker Spaniel were examined by the vet, and then euthanized. That’s two dogs we couldn’t save with the so-called “Missouri Solution”.

What does it take to close this hell hole down? A news conference?