USDA Breeder Licensing – Why ‘Teachable Moments’ Matter

USDA Breeder holding 4 puppies

 

To err is human. But in just about any endeavor, minor errors or the opportunity to ask questions of an expert also provide a valuable opportunity to learn. So-called “teachable moments” are typically related to experience and defined as the moment at which a person is most able to learn. These moments provide the opportunity for a person to improve outcomes and performance, or learn an important lesson that emphasizes positive overall outcomes over minor negatives or errors made on the path to success. The general principle of teachable moments is widely recognized among a range of environments from child rearing to scientific research, education, and even to criminal justice.

For years, teachable moments have been part of USDA APHIS Animal Care Division’s approach to correcting minor, non-welfare-related issues among Animal Welfare Act (AWA) licensees. They are an opportunity to educate and assist USDA licensed breeders in improving their operations, animal care, and overall welfare outcomes. Today, teachable moments and educational opportunities are more important than ever because US demand for pet puppies vastly outstrips supply. (The US Pet Productions Association estimates demand at more than eight million puppies per year.)

For new or future pet breeder licensees, there are few resources other than the American Kennel Club and USDA to learn the science and art of canine breeding and animal husbandry in a hands-on environment. Sadly, few “experts” in canine welfare outside the USDA or traditional breeding organizations have much, if any, hands-on experience in canine breeding.

Until recently, USDA’s Animal Care Division of APHIS, which oversees implementation of the AWA rules pertaining to professional or high-volume breeding operations (defined to include anyone who maintains more than four intact females and sells one offspring sight unseen), have provided programs and outreach to assist breeders on practical matters; assistance on improving welfare and operations; and in-person teachable moments to assist licensees in improving operations that improve compliance and positively impact canine welfare.

Now, some anti-breeder groups, including PETA, HSUS and ASPCA, are attempting to stop this.

These groups typically have little animal breeding or husbandry experience and often misinterpret education or teachable moments as undermining welfare. The fact is, educational and outreach programs do the very opposite. Implementation of educational programs and teachable moments has enabled 96 percent of USDA pet breeder licensees to achieve compliance with AWA regulations.

Implementation of educational programs and teachable moments has enabled 96 percent of USDA pet breeder licensees to achieve compliance with AWA regulations.

The most recent effort in this area is language (specifically, Section 755) in the Fiscal Year 2023 Agricultural Appropriations bill that was recently passed by the U.S. House (a Senate version has yet to be marked up).

It contains language that would prohibit funding to implement any activities related to:

  • (a) The permitting of non-recording of observed violations of the AWA or its regulations on official inspection reports;
  • (b) The prioritizing of education or collaborative approaches to violations or noncompliance ahead of enforcement under the AWA.

 

This raises several important concerns:

  • Should the House language be interpreted to mean an inspector is prohibited from suggesting changes? Preventing inspectors from conveying questions and concerns or educating regulated entities would be detrimental to the health and well-being of the animals.
  • With a prohibition on “education” and “collaborative approaches,” how would the agency promulgate and implement new regulations – a process that typically involves a 60-day public comment period under the Administrative Procedures Act?
  • Education is a critical part of the regulatory process. Currently, APHIS works with licensees and registrants to help them understand and comply with the newly promulgated contingency plan regulations. The new House language could be interpreted as prohibiting that kind of training. It could also be interpreted as prohibiting agency staff from even participating in any kind of meeting with the regulated community.
  • As part of APHIS’s new licensing regulations, the agency has encouraged licensees to request a visit before the formal pre-license inspection. This is something the agency has found to be constructive as part of their effort to ensure compliance with AWA regulations; however, it would likely be prohibited under this proposal.

Cutting funds to key educational and outreach programs and emphasizing enforcement would create a sea change in how USDA works with dog breeders. It would move the current emphasis of collaborative relationships in support of ethical, high-quality practices through outreach and education to a “gotcha” scheme that fails to allay preventable welfare failures, and would allow for avoidable harm to dogs simply in order to implement harsh penalties.

Passage of such legislation will further send the message that Americans don’t care about ethical breeding or support animal welfare. At a time when the demand for pets is stronger than ever, fewer US-bred pets means more will be imported from countries with few, if any, animal welfare and health requirements.

In a letter dated September 19, numerous other organizations joined AKC in asking Senate Appropriators to not diminish educational opportunities for breeder licensees as done by the House. Instead, we ask that they provide additional funding for inspectors and promote education, collaboration, and animal welfare. Other organizations joining this letter include the American Veterinary Medical Association, the Association of American Veterinary Medical Colleges, the National Animal Interest Alliance, the National Association of Biomedical Research, the Pet Advocacy Network, U.S. Sportsmen’s Alliance, and others.

At a time when the demand for pets is stronger than ever, fewer US-bred pets means more will be imported from countries with few, if any, animal welfare and health requirements.

To learn more, visit AKC’s Legislative Action Center, AKC GR’s Alert, or view a copy of the joint letter.

 

About the Author

As Vice President, Government Relations for the American Kennel Club, Sheila Goffe leads the AKC’s efforts in the public policy arena, including working to protect the rights of all dog owners and promote responsible dog ownership. She oversees AKC legislative policy strategy and AKC outreach at the federal, state, and local levels. She also serves as AKC staff lead for the AKC Detection Dog Task Force, Service Dog Pass, and other key programs.

Sheila joined AKC in 2006. Prior to working for the American Kennel Club, she was a Senior Legislative Analyst/Editor and Deputy Director of Editorial Product Development for Congressional Quarterly in Washington, DC. Previous experience included federal legislative staffing and advocacy, work as an editor and analyst for The Economist Intelligence Unit, and serving as an adjunct in Political Science/Comparative Politics at the State University of New York/Stony Brook. She also owns, breeds, and shows Siberian Huskies.

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