The USDA now has a basic breakdown of all the Comments submitted for Docket No. 98-106-4:
Postal Comments
http://www.aphis.usda.gov/ppd/rad/LPOC/98-106-4.txt
E-Mail Comments
https://web01.aphis.usda.gov/regpublic.nsf/fc818cf6f3e7a7f585256eb5003ba6a9?OpenView
and the PoJ Comment is ID No. 5053!
Web Comments (NOTE: almost impossible to navigate and the server keeps going down)
I love animals in general, including mice. I see two areas of concern to this site - rodents being used for scientific research/testing, and rodents being used as feeders for pet snakes, etc.
As far as the first area…While I strongly agree that all animals need to be respected and treated as humanely as possible, I also contend that mice have proven invaluable to helping further legitimate (yes, there have been many illegitimate, but I do not put forth those examples as valid arguments, and rightfully condemn them…) research that has led to treatments and cures that have provided relief - and saving of millions of lives - to humanity. Mice are heros in my book for that reason alone. I’ll also be the first to say quit using them for that purpose if another equal or better method of scientific inquiry/testing is found, but for now, there isn’t a better one.
The second area - used as feeders - that one has solutions already. I have read that there are viable, nutritionally equivalent (maybe even superior), and affordable alternatives to live feeding of rodents to snakes, etc.
628 individuals emailed the USDA to let them know that:
- they believe rats and mice are animals
- they believe rats and mice are not “food and fiber”
- they want specific standards of humane care for rats and mice
- they believe a few pennies extra per rat or mouse is well spent if it ensures their health and well being!
Thank you!
The USDA Letter Generator is now “offline” - thanks to everyone who took the time to write in!
Try the Senator Letter Generator! Now also the Secretary of Agriculture Letter Generator!
Secure breeding environments and appropriate good-health measures are key. Wild rats and mice (and other wildlife) are capable of sharing their creepy-crawlies with their domestic cousins. Furthermore, these domesticated rats and mice will share them with other animals at their intended destinations and then, ultimately, with you!
Oxyuriasis - Syphacia muris (pinworms):
Rat is natural host.
Transmission fecal-oral, self-cleaning.
Oxyuriasis - Syphacia obvelata (pinworms):
Mouse, hamster, gerbil is natural host.
Can affect rats (when housed in same room).
Transmission fecal-oral, self-cleaning.
Oxyuriasis - Aspiculuris tetraptera (pinworms):
Mouse, rat (?) is natural host.
Transmission fecal-oral.
Acariasis - Radfordia ensifera (fur mites):
Rat is natural host.
Transmission eggs (results in barbering, secondary skin infections, ulcers).
Acariasis - Radfordia affinis (fur mites):
Mouse is natural host.
Transmission eggs (results in barbering, secondary skin infections, ulcers).
Pneumocystosis - Pneumocystis carinii:
Mammal is natural host.
Transmission inhalation of spores (it’s a fungus).
Trichophyton mentagrophytes (ringworm):
Wild rat is natural host.
Can affect rats, mice, guinea pigs, cats, dogs, humans.
Transmission direct contact.
Hymenolepis nana (tapeworm):
Wild mouse is natural host.
Can affect mice, humans.
Transmission fecal-oral(?).
We can’t prevent bacteria from being, but we can limit the harm done. Poor breeding practices and facilities contribute to greater risk. Clean bedding and ample space (the more overcrowded, the more likely they are to attack cagemates) alone would reduce such risk to them, to other animals, and to us!
Murine Respiratory Mycoplasmosis:
Rat and mouse is natural host.
Can affect hamsters, guinea pigs.
Transmission airborne.
Pseudotuberculosis:
Rat and mouse is natural host.
Can affect hamsters, guinea pigs.
Transmission fecal-oral.
CAR bacillus:
Rat, mouse, rabbit is natural host.
Transmission direct contact
Tyzzer’s Disease - Clostridium piliforme:
Japanese waltzing mice is natural host.
Can affect numerous rodent species, rabbits, carnivores, horses, monkeys, and humans.
Transmission fecal-oral (spores).
Staphylococcosis:
Rodent (all) is natural host.
Transmission dirty bedding.
Streptobacillus moniliformis (rat bite fever):
Wild rat is natural host.
Can affect rats, mice, cats, humans.
Transmission bite wounds, scratches, aerosol exposure.
Leptospira icterohemorrhagiae:
Wild rat is natural host.
Can affect rats, humans.
Transmission skin wounds, contact, dirty bedding.
Viruses happen and we can’t do much about that, but we should be concerned about knowingly sending sick animals to their intended destinations! They can get everyone sick and that can become quite costly!
Parvovirus - RV:
Rat (and wild) is natural host.
Can affect hamsters, mice, kittens.
Transmission fecal-oral, urine, milk, direct contact, aerosol exposure.
Paramyxovirus - Sendai Virus (SV):
Rat and mouse is natural host (moreso mouse).
Can affect hamsters, guinea pigs, rabbits, marmosets(???).
Transmission airborne, direct contact, aerosol exposure.
Paramyxovirus - Pneumonia Virus of Mice (PVM):
Mouse is natural host (moreso mouse).
Can affect rats, hamsters, gerbils, guinea pigs, rabbits, mongooses(???), and perhaps monkeys and humans.
Transmission direct contact.
Reovirus - Infectious Diarrhea of Infant Rats (IDIR):
Rat is natural host (moreso mouse).
Can affect humans.
Transmission oral-fecal.
Lymphocytic Choriomeningitis Virus (LCMV):
Wild mouse is natural host.
Can affect mice, hamsters, humans.
Transmission fecal-oral.
Hemorrhagic Fever with Renal Syndrome (HFRS):
Wild rat is natural host.
Can affect humans.
Transmission dirty bedding, saliva, respiratory.
North American Pet Distributor Inc. (NAPD) is the Upper Midwest’s largest supplier of small animals to the pet industry.”
Click here to see where your pet rats are coming from.
* They “receive hundreds of animals.” They haven’t the space to accommodate the quantity and so many suffer as a result (overcrowding, death, etc)
* Their automatic waterer went awry and drowned sixteen rats [3rd paragraph]. Which means the dead rats were likely stuggling in their tubs for more than 48 hours without anyone noticing the problem. [In the 1950’s Curt Richter performed a series of gruesome experiments at Johns Hopkins whereby he discovered that domestic rats would swim for 60-80 hours before giving up…never thought the results of those experiments would be useful…] Even worse, the drowning incident wasn’t the first, “[t]hat happens sometimes,” according to a NAPD supervisor. . .
* Rats and mice are so overcrowded that they have no other choice but to walk over one another [see images, video].
* Sick animals are euthanized in plastic bags…some more than once…and not according to AVMA standards [5th paragraph].
* Rats flipping showed signs of neurological problems [7th paragraph].
* They sell knowingly sick animals to Petco under the assumption that Petco can recognize illness and will ‘return’ them. [4th paragraph] Don’t assume this is just a Petco phenomenon, either. (And, no, a Petco buyer can’t recognize illness)
And don’t forget to check out the video and additional photos.
More on this:
Kevin Hanson, co-owner of North American Pet Distributors, says
“Animals are shipped to us by vendors, and sometimes they come to us in bad conditions,” he said. “They often have diarrhea, which is often caused by stress. We make them healthy. We can’t ship them unless they’re in good (health).”
Why is the connection between feeder rats and fancy rats so important? The USDA has already created one completely artificial distinction between rats of the genus Rattus and mice of the genus Mus bred for use in research - and everyone else. Laboratory rats and mice are identical to non-laboratory rats and mice; however, the research community insisted on creating two categories of animal to keep the Animal Welfare Act (AWA) out of laboratories.
Now, another special interest group wants to slice rats of the genus Rattus and mice of the genus Mus into yet another independant category, ‘feeder’, in order to keep the AWA out of mass breeder warehouses - rodent puppy mills.
So, we have the same animals, Rattus norvegicus and Mus Musculus, already divided arbitrarily into ‘bred for use in research’ and not ‘bred for use in research’ in order to satisfy one special interest. In order to satisfy yet another special interest, the group will be divided again into ‘feeders’ and ‘non-feeders’. Despite the fact that feeder and pet rats are not only biologically identical animals: they come from the same source.
What a regulatory nightmare! The same animal, regulated under at least three different standards, depending on a completely arbitrary designation made by profit-making entities.
If you ever thought that the “fancy” rat or mouse bin and “feeder” rat or mouse bin at your favorite pet store meant something, think again! Most of the time this distinction is the result of human intervention: Someone somewhere found one rat or mouse to be more appealing than the other (and thus worth more moeny than the other) - the more appealing of the two became friend (fancy) while the other became fodder.
Why does this matter? Because fancy and food come from the same sources. People who breed rats and mice for food aren’t naive - they know that they can get more money for a “fancy” rat or mouse than they can for an unappealing “food” rat. There’s one such example here:
http://www.RemarkableRodents.com
Although appealing because they produce a great variety daily, it seems likely that their excessive production is not solely appreciated by the rat and mouse lovers of the world (and while you’re there, don’t forget to scroll down and see their breeding setup - 33 1/3 rats per tub!):
Remarkable Rodents Variety and Tubs
Why are some “fancy"? Check out the prices:
Remarkable Rodents Prices
As another example, this was found on Kingsnake:
And another, from Backwoods Farm, Inc. website:
the ‘pet’ rats. . .
* dark skin hairless - $8.95
* masked hairless - $9.95
* hairless masked dumbo - $10.95
and the live ‘feeder’ rats. . .
* small - $2.00
* medium - $3.00
* large - $4.00
* JUMBO! - $5.00
In order to try and create a balanced sampling of typical feeder rodent conditions in the United States, we have all had to look at quite a few photographs, good and bad. For some reason, this particular image haunts me - something about the excited rat jumping up on the wire next to the red water valve and the phrase, “. . . no shavings - it is a wash down system, straight into the sewer!”.
I know, we aren’t supposed to make the issue personal, but the image of that rat will remain with me long after this campaign is over.
The photo was originally found on Kingsnake.com, and not posted by the alleged owner of the cage system, so we cannot say with any certainty who is responsible for the multiple problems:
* rats housed on bare wire floor
* overcrowding of animals in cage
* unsanitary conditions
* wire of cage either rusted or dirty
* bottom pan filled with fecal material and puddles of urine or water (possible evidence of dried urine - pale rings)
* cage as shown unable to be properly sanitized
David Boggs Reptiles
The ‘David Boggs Reptiles’ photographs have been removed. Instead, we would like to list the steps Mr. Boggs has taken to ensure his feeder mouse stock is kept and treated in a humane manner.
* the mice are kept on a substrate of aspen pellets and flakes, not pine or cedar which are dangerous for both mouse and reptile health.
* each mouse pan is cleaned once every five days, and the pan sterilized (there is no ‘mouse smell’).
* the mice are provided with fresh water and Mazuri 9F mouse diet.
* the ‘mouse room’ is kept at a steady temperature, 76-78 degrees.
* the mice are kept separate from any reptiles or other animals for several reasons; to keep the mice from becoming stressed, and to prevent the transmission of disease to the colony.
* the mice are Swiss-Webster, purchased from SAS Supply. The breeding ratio is maintained at six females to one male, and the current space to mouse ratio exceeds NIH guidelines.
* the mice are euthanized in a tub filled with concentrated CO2 gas and dead within two minutes - in compliance with AVMA Euthanasia guidelines.
* and, most important, USDA inspectors may drop by for an unannouced visit at any time - the mice will be ready.
We would like to thank Mr. Boggs for taking the time to speak with us and describe his feeder operation in minute detail, down to the fact that his breeding females are all sisters so they feel more comfortable in the colony (the males are changed out to prevent inbred stock).
Rats R Us
San Diego County Animal Control had been receiving complaints about ‘Rats R Us’, a mass breeder of rats for snake food, since 1996. Neighbors of Peter Springer, co-owner of ‘Rats R Us’, had been forced to endure the horrible stench emanating from the ‘Rats R Us’ barn and dead rats appearing in their yards. Encinitas councilwoman Maggie Houlihan, who happened to live up-hill from ‘Rats R Us’, demanded action be taken after she found dying rats crawling across her property. Animal control officers made their move - in June of 2002.
The result? A minimum of 20,000 decayed, dead, and dying rats. A smell so over-powering that officers could only stay in the barn for three minutes at a time, and were later forced to wear gas masks. Fifty to sixty animals crammed into cages designed to hold eight. Rampant disease, cannibalism, half-eaten body parts left to rot. Rats so crowded they struggled to expand their rib cages and breathe. And in the saddest twist of all, the barn floor covered in rat poison so any escapees would be dead before reaching safety.
‘Rats R Us’ was in the business of suppling live and frozen rats to Los Angeles area businesses, zoos, and pet shops for reptile food. Apparently, Peter Springer believed he was being unfairly targeted by animal control officers who didn’t understand the nature of his business. “We attempt to care for them, but some will die.”
In truth, every ‘Rats R Us’ rat died, because officers were forced to spend three days humanely euthanizing the animals with carbon dioxide gas. Not a single rat made it out of ‘Rats R Us’ alive, including the sixty-eight animals initially seized.
Animal Control faced one huge obstacle in stopping Peter Springer and ‘Rats R Us’: a lack of guidelines for the proper care of rats in mass breeding situations. However, the County of San Diego District Attorney’s Office, in an unprecedented move, filed one count of felony animal cruelty against Peter Springer in August of 2003. In September, Mr. Springer pled not guilty at his arraignment and was freed on his own recognizance pending trial. His business partner, Bob Turner, was never charged due to a lack of evidence linking him to the alleged abuse. In October of 2003, Mr. Springer pled guilty to one count of misdemeanor animal neglect under a plea bargain arrangement with the District Attorney’s Office. According to John Carlson, Regional Director, County of San Diego, Department of Animal Services, “[i]n this case, the conditions were so deplorable that prosecution was the only option. If federal regulations and inspections had beeen in place, these conditions could never have developed to this state” (emphasis added).
Mr. Springer was placed on three years of probation, during which time he may not own or breed any rodents, nor own any animals except for his current dog. If Mr. Springer violates his probation, he could spend up to one year in jail. In addition, Mr. Springer must attend three sessions of counseling and serve ten days of community service picking up trash on the highway. ‘Rats R Us’ is now defunct, the property has been sold, and Mr. Springer plans to move out of the neighborhood.
The ‘Rats R Us’ case is a legal anomaly for three reasons. First, animal cruelty cases in general are extremely difficult to investigate and prosecute, making formal charges against offenders rare. Second, the ‘Rats R Us’ case may be the only American example of state prosecution for animal cruelty or neglect where the victim was a domestic rat. Third, the case vividly illustrates the need for greater oversight and inspection of mass breeding facilities. Domestic rats are not officially given protection under the federal Animal Welfare Act (AWA), therefore, ‘Rats R Us’ was never inspected by the United States Department of Agriculture (USDA), unlike identical businesses breeding gerbils, hamsters, guinea pigs, rabbits, or other ‘pocket pets’. In most jurisdictions, no government entity has the authority to monitor conditions at rat/mouse breeding facilities. Animal Control officers may only enter such a facility after a legitimate complaint has been filed.
Defiant to the end, Peter Springer has complained his neighbors and county officials are animal-rights extremists and also claims to have spent eight hours per day caring for his furry charges. In Mr. Springer’s own words, “I could almost talk to them.”
Apparently, he needed a translator.
* Kevin Clerici, Officers Find Squalid ‘Mess’ in Barn Used to Breed Rats, San Diego Union-Tribune, July 18th, 2002.
* E-mail from John Carlson, Regional Director, County of San Diego, Department of Animal Services, to Lydia Peirce-Dougherty, Attorney, Eadie’s House, ‘Rats R Us’ Case Information (June 7, 2004, 14:20:06 p.m. MST)(copy on file with Eadie’s House).
* Daniel Evans, Owner of Rat Business Faces Charge of Cruelty, San Diego Union-Tribune, August 13, 2003.
* Marty Graham, Rat Breeder Faces Felony Charge of Squalid Keep, North County Times, August 15th, 2003.
* MSNBC, Microsoft Corporation, San Diegan Accused of Cruelty to 35,000 Rats, (last modified August 13th, 2003)
* MSNBC, Microsoft Corporation, Rats R Us Owner Pleads Guilty to Animal Neglect (last modified June 3, 2004)
* Dana Littlefield, Rat Breeder Receives Probation, Public Service for Animal Neglect, San Diego Union-Tribune, October 10, 2003.
Glossary of Acronyms
AAVS: American Anti-Vivisection Society
ALDF: Animal Legal Defense Fund
ALF: Animal Liberation Front (considered a domestic terrorist organization by the DOJ)
ANPR: Advance Notice of Proposed Rulemaking
APHIS: Animal and Plant Health Inspection Service
ARDF:Alternatives Research and Development Foundation
AVMA: American Veterinary Medical Association
AWA: Animal Welfare Act
CFR: Code of Federal Regulations
DOJ: United States Department of Justice
FOIA: Freedom of Information Act (E-FOIA refers to the Electronic Freedom of Information Act Amendments of 1996, giving electronic access to certain FOIA materials)
FR: Federal Register
NARA: National Archives and Records Administration
NIH: National Institutes of Health
NIMH: National Intitute of Mental Health (of Mrs. Frisby fame. . .)
OLAW: Office for Laboratory Animal Welfare
PHS: Public Health Service
USDA: United States Department of Agriculture
A space reserved for Divine Intervention. . . we need some. . .
here he be - Bato Kannon
and Ganesh riding his rat vahana Mooskiha (thank you, Claire!)
a closer look at Mooshika
A few bad apples can spoil the Kingsnake.com barrel - right?
Precious Pets and Habitats
I’m going to take a wild guess these rats do not not qualify as ‘precious’.
Problems:
* rats housed on bare galvanized wire floor
* severe over-crowding
* exposed wood absorbs urine and bacteria; impossible to properly sanitize
* what appear to be an excessive number of food pellets rolling freely on floor among the animals - extremely unsanitary
Although this feeder breeder was located on Kingsnake.com, I would like to mention how helpful and professional the folks at Kingsnake.com have always been towards our rat rescue and education efforts.
According to the JVK Mice site, “[j]ust as much time and care go into our feeders as to our other animals.” Several photographs accompany this statement - judge for yourself.
exterior of mouse barn
interior shot of mouse barn - how many mice are in that bin?
Problems:
* animals housed on what appears to be pine bedding (bedding is dark, an indication of wetness, in addition to fecal material)
* exposed wood in barn, including floor, cannot be properly sanitized
* possible overcrowding of animals in pans
Excerpts from, St. Augustine Record, aka, another argument for the absolute necessity of enforced regulations (Elliott Jones, I’m a Rat Man, Vero Beach Press Journal (July 2, 2004). :
1. Handling -
* Photo depicts man “tossing a rat from one bucket to another:”
* Not sure what an 11/2lb rat is, but a rat shouldn’t be “dangling…by its tail.”
2. Secure environment -
* An “electrified wire” deters “carnivorous raccoons living in the woods” but, presumably, lets everything else in.
* Wild rodents are poisoned
note: Poisoned rats can still walk and can still get in thus infecting and/or attacking the population of rodents enclosed “in cat litter boxes in racks.")
* Wild “rat snakes” slither in (but not out) with little effort.
note: any parasites, diseases, etc that a wild snake carries will undoubtedly affect its domestic counterpart and the rats that come into contact with these wild rat snakes can carry the parasites, diseases, etc to their future host if fed live.
3. Veterinary intervention - none
* They rely on “homegrown medical skills.”
Another note: Although their initial stock was “disease and pest free” they certainly are no longer. If they were, certainly they would not need these measures as stated on their website:
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