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!

11. Should rats and/or mice other than rats of the genus Rattus and mice of the genus Mus bred for use in research continue to be regulated under the general standards in subpart F of part 3?

No. Rats of the genus Rattus and mice of the genus Mus, not bred for use in research, should not continue to be regulated under the general standards in Subpart F of Part 3.

12. As mentioned above, part 3 of the regulations contains specifications for the humane handling, care, treatment, and transportation of animals covered by the AWA. Among other things, the standards in part 3 address the following considerations:

Facilities and Operations (including space, structure and construction, waste disposal, heating, ventilation, lighting, and interior surface requirements for indoor and outdoor primary enclosures and housing facilities);

Animal health and husbandry (including requirements for sanitation and feeding, watering, and separation and classification of animals); and

Transportation (including specifications for primary enclosures, primary conveyances, terminal facilities, and the feeding, watering, care, and handling of animals in transit).

Should specific standards be developed for rats and/or mice other than rats of the genus Rattus and mice of the genus Mus bred for use in research?

Yes.

If so, what minimum standards that would be appropriate for those animals, including requirements for facilities and operations, animal health and husbandry, and transportation? Please submit specific data to support any suggested standards.

The specifications for the care and use of rats and mice contained in the Guide are appropriate and adequate to provide for the humane handling, care, treatment, and transportation of such animals.

13. As noted above, research institutions funded at least in part by the Public Health Service of the U. S. Department of Health and Human Services are required to follow a program of animal care and use that is consistent with the National Research Council’s Guide for the Care and Use of Laboratory Animals. To eliminate confusion and simplify compliance for entities that must comply with the regulations and the Guide, we have, whenever possible, made the standards in part 3 of the regulations consistent with the program of animal care and use in the Guide. If specific standards should be developed for rats and mice other than rats of the genus Rattus and mice of the genus Mus bred for use in research, are the specifications for the care and use of rats and mice contained in the Guide appropriate and adequate to provide for the humane care, handling, treatment, and transportation of those animals?

Yes.

If so, please submit specific data to support the adoption of the Guide’s specifications for rats and mice.

14. Comments are invited concerning the number and size of entities that use rats and mice, except for rats of the genus Rattus and mice of the genus Mus bred for use in research, for purposes covered by the AWA. (Such entities may include dealers, research facilities, exhibitors, operators of auction sales, and carriers and intermediate handlers of rats and mice covered by the AWA that are sold as pets at the wholesale level, transported in commerce, used in exhibits, or used for research, teaching, testing, or experimentation purposes.)

15. What is the number of each species of rats and mice, except for rats of the genus Rattus and mice of the genus Mus bred for use in research, that are currently sold as pets at the wholesale level, transported in commerce, used in exhibits, or used for research, teaching, testing, or experimentation purposes?

16. Comments are invited concerning the current physical structures, equipment, staffing, licensing, and paperwork used in the handling, care, treatment, and transportation of rats and mice, except for rats of the genus Rattus and mice of the genus Mus bred for use in research, for purposes covered by the AWA. If you are submitting suggested standards for rats and mice in response to question 12 or believe that we should establish specific standards for covered rats and mice that are consistent with the Guide (see question 13, above), please address how those standards would affect facility operations.

Facilities and Operations (including space, structure and construction, waste disposal, heating, ventilation, lighting, and interior surface requirements for indoor and outdoor primary enclosures and housing facilities);

Citing the NIH “Guide for the Care and Use of Laboratory Animals”,
* Allow for the normal physiologic and behavioral needs of the animals, including urination and defecation, maintenance of body temperature, normal movement and postural adjustments, and, where indicated, reproduction.
* Allow conspecific social interaction and development of hierarchies within or between enclosures.
* Make it possible for the animals to remain clean and dry (as consistent with the requirements of the species).
* Allow adequate ventilation.
* Allow the animals access to food and water and permit easy filling, refilling, changing, servicing, and cleaning of food and water utensils.
* Provide a secure environment that does not allow escape of or accidental entrapment of animals or their appendages between opposing surfaces or by structural openings.
* Are free of sharp edges or projections that could cause injury to the animals.
* Allow observation of the animals with minimal disturbance of them.

and,
* Secured environment/enclosure protecting those caged from predators (including their own wild kin).
* Sufficient humidity (relative humidity: 30-70%)
* Adequate temperature (18 - 26 Celcius) where control of temperature fluctuation exceeds actual temperature in importance.

Animal health and husbandry (including requirements for sanitation and feeding, watering, and separation and classification of animals);

* sanitation: enclosures should be clean, dry, and should not smell of ammonia (toxic gas resulting from the chemical decomposition of urea). From NIH, “The maintenance of conditions conducive to health involves bedding change (as appropriate), cleaning, and disinfection. Cleaning removes excessive amounts of dirt and debris, and disinfection reduces or eliminates unacceptable concentrations of microorganisms.”
* feeding: rats and mice regulate food intake and as such, food (for example, a nutritious pelleted formulation) should be non-contaminated, nutritional, available, and accessible at all times.
* watering: the water source should be clean, functional, and accessible at all times. the water itself should be clean.
* separation and classification: rats and mice are animals of prey and, as such, rats should coexist with same-sex other rats and mice should coexist with same-sex other mice except in instances of breeding. One should take heed in understanding that as animals of prey, rats and mice are territorial and protective of their setting, their community, and their young. An older rat or mouse will ‘fight to the death’ to protect that which is his if the intruder is not a member of the existing established community.

and Transportation (including specifications for primary enclosures, primary conveyances, terminal facilities, and the feeding, watering, care, and handling of animals in transit).

Rats and mice are mammals and respond adversely to drastic fluctuations in temperature. In addition to ensuring a static temperature not to reach 32 Celcius or fall 10 Celcius for any extended period of time, one must ensure that the food present is adequate and in plentiful amount for the duration of the journey and that a water source (fruits and vegetables, for example) is present and replenished if a single journey exceeds 8 hours.

It seems that breeders and distributors are likely to argue that minimum standards are already being met and if that is indeed the case, devising and enforcing minimum standards should be of no consequence to such facilities.
As a consumer, however, I disagree that such minimum standards are met based on the breeder’s free choice alone and that such standards should be devised and enforced in order to offer the end consumer protection, the right to complain and taken seriously.
If, in fact, minimum standards were met, it would not be common for us, the rat community, to purchase rats or mice with advanced pneumonia due to lack of cleanliness, lack of temperature control, lack of medical care, and poor breeding practices.
If, in fact, minimum standards were met, we, the rat community, would not have to have a veterinarian resolve the guaranteed mites or lice problem always included with any rat purchase.
If, in fact, minimum standards were met, we, the rat community, would not find ourselves dealing with rat and mouse-communicable illnesses such as SDAV, KRV, RCV which adversely affect our existing populations of rats and mice and which can also affect other small rodents.
If, in fact, the minimum standards were met, we, the rat community, would not find ourselves treating rat-human communicable fungal or parasitic problems such as ringworm or pinworm. In addition, ringworm and pinworm are communicable to all species (and thus every animal in a zoo or a pet store); ringworm via contact, pinworm via air or fecal ingestion.
If, in fact, the minimum standards were met, the predator-owning community would not need to treat for mites on a regular basis for their pets would not be otherwise exposed to carriers of the parasite.
And, if, in fact, the minimum standards were met, retail outlets offering guarantees would not lose money by having to provide immediate care for a sick or injured rat supplied by such mass breeders and dealers nor would they have to make the choice to freeze apparently ill stock for the purpose of obtaining a DOA refund from the breeder/dealer.

Minimum standards for rats of the genus Rattus and mice of the genus Mus bred for uses other than research should be devised and enforced to afford such rats and mice, typically bred for pets and food, the right to have a quality life.

17. What are the potential economic effects, in terms of time and/or money, on entities that may be affected if we were to establish specific standards for rats and mice covered by the AWA? (Such entities may include dealers, research facilities, exhibitors, operators of auction sales, and carriers and intermediate handlers of rats and mice covered by the AWA that are sold as pets at the wholesale level, transported in commerce, used in exhibits, or used for research, teaching, testing, experimentation, or exhibition purposes.)

See #16
and….[more to come]

18. Do you have any other specific concerns or recommendations pertaining to the regulation of rats and mice other than rats of the genus Rattus and mice of the genus Mus bred for use in research?