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!
Animals do have their very own PAC (political action committee) Humane USA:
The Humane USA site lists the ‘Humane Scorecard’ - the voting record for each Congress on animal issues. In addition, the site lists the ‘best’ and ‘worst’ members of Congress on animal issues (something to remember when writing those letters).
In addition, there is a ‘Congressional Friends of Animal Caucus’ (CFA) co-chaired by Congressmen Christopher Shays and Tom Lantos. Below is the last known contact information for the 26 member caucus:
Congressional Friends of Animals
2217 Rayburn Office Bldg
WASHINGTON, DC 20515
Tel: + 1 (202) 225-3531
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?
But Lydia also advises giving the senators with agricultural connections special attention. You can search for them here.
And here is a lovely sample letter to be sent to Senators associated with Agriculture:
Honorable (full name)
__(Rm.#)__(name of)Senate Office Building
United States Senate
Washington, DC 20510
October ?, 2004
RE: USDA/APHIS ANPR: Animal Welfare: Regulations and Standards for Birds, Rats, and Mice (Docket No. 98-106-4).
Dear Senator:
I am writing you as a constituent in *where do you live?* to win your support for extending the definition of ‘animal’ in the Animal Welfare Act to include all rats and mice, not bred for use in research, as proposed by the Department of Agriculture (USDA), Animal and Plant Health Services (APHIS), Advance Notice of Proposed Rulemaking, Docket No. 98-106-4, published in the Federal Register on June 4th, 2004 (Volume 69, Number 108).
In accordance with the September 2000 settlement of ARDF vs. Glickman, in the U.S. District Court for the District of Columbia, the USDA has finally started the process of rulemaking on the regulation of rats and mice under the AWA. As you are aware, the Helms Amendment to the 2002 Farm Bill excluded rats of the genus Rattus and mice of the genus Mus, bred for use in research, from protection under the Animal Welfare Act. However, the USDA is still considering minimal protection for the millions of rats of the genus Rattus and mice of the genus Mus currently entering the stream of commerce through the pet trade.
According to Robert Johnson, writing in the Wall Street Journal, 180 million mice and rats were raised in the United States during the year 1999, and the business of supplying so-called ‘feeder’ rodents for reptile food was a 235 million dollar per year industry. An industry that is still completely unregulated, resulting in millions of diseased and injured animals entering the stream of commerce. Due to this capricious oversight, municipalities across the country are forced to ‘police’ breeder operations with no guidance or funding, leading to tragedies such as the appalling 2002 ‘Rats R Us’ case in San Diego County, California, involving over 20,000 domestic rats. In the words of 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 been in place, these conditions could never have developed to this state.” Mr. Carlson was referring to: diseased/dying rats crawling across neighboring properties; an ammonia concentration so high animal control officers were forced to wear gas masks to work inside the barn structure; 50-60 rats crammed into cages designed to hold eight animals; cannibalism, disease, and carcasses left to rot.
Such conditions are not unusual in mass animal breeding operations, although prosecution of offenders is extremely rare. Research into the typical existence of a mass-bred rat or mouse will reveal several constants: overcrowding; contaminated or inappropriate food; cages and enclosures that cannot be sanitized in the event of disease; an excess of fecal material and urine resulting in high concentrations of ammonia fumes. Rats and mice raised in such conditions enter the stream of commerce as ‘pocket pets’; brought into America’s homes as companion animals. Such rats and mice almost always incur immediate medical expenses because they carry various parasites, suffer from respiratory diseases, and suffer from the effects of malnutrition and often bodily injury from mishandling. The average consumer has no idea where his or her pet rat originated from - and there are millions of family rats and mice in the United States. How horrible for a child to watch his or her first pet die within weeks from a completely preventable disease, such a pneumonia due to ammonia damage in the lungs.
In addition to pets, some rats and mice end up as ‘feeders’, or animals to be used as food by reptiles and raptors. The word ‘feeder’ is an artifact of the pet industry, and there is no difference between a ‘feeder rat’ and ‘pet rat’ (or ‘fancy rat’). Under pressure from the pet industry, the USDA is considering placing ‘feeder’ rats and mice in the category of ‘food and fiber’ and thus removing such animals from AWA protection. Mass breeders and rodent brokers may separate rats and mice by perceived consumer desires, such as interesting coat color or ear placement, in order to increase sales. However, the end status of a rat or mouse as a ‘pet’ or ‘feeder’ is always within the control of the consumer - not the pet store, broker, or breeder. Rats and mice are far too mingled in the stream of commerce to permit arbitrary designations created only to evade basic humane standards on the part of breeders and brokers. In addition, other common ‘feeder’ animals, such as guinea pigs (Cavia porcellus), hamsters (Cricetus cricetus, et al.), and rabbits (Oryctolagus cuniculus) are regulated by the Animal Welfare Act, and are not separated into ‘feeder’ and ‘pet’ categories.
In conclusion, I would ask you to encourage the USDA in their rulemaking efforts on behalf of rats of the genus Rattus and mice of the genus Mus, not bred for use in research. We need federal guidelines and oversight in order to properly monitor conditions and bring successful prosecutions for animal cruelty against violators. The rat and mouse breeding industry has been allowed to balloon without regulation for too long, with disastrous results.
Sincerely,
Your Name!
Your Address!
Your Telephone Number!
Your E-Mail Address!
1) Be courteous.
2) Put your name and address/location at the very beginning of the letter.
3) Begin the letter with “Dear Senator LastName”
4) Briefly state your issue (you would like to see the USDA regulate the care of rats and mice in the pet/feeder industry). Specifically, [Docket No. 98-106-4] - Animal Welfare; Regulations and Standards for Birds, Rats, and Mice.
5) State *why* - How will this change impact you?
6) Be courteous.
For example (but remember: a letter written in your own words always means a lot more!):
My Name
My Address
My City, State ZIP [< ----IMPORTANT]RE: [Docket No. 98-106-4] - Animal Welfare; Regulations and Standards for Birds, Rats, and Mice [< ----IMPORTANT]
My Senator’s Name
My Senator’s AddressDear Senator MySenator’sLastName,
Hopefully you’ve had the pleasure within your lifetime to share your home with a family pet. If you have, I’m certain you value their good health and the great love pets bring to your home and family.
I, myself, share my home with pet rats. And despite the seemingly excessive vet care costs (_$###.##_ annually), we have _#_of_rats_.
I am not alone either. Did you know that rats have been growing in popularity as pets since the early 1990s? There are several Internet groups devoted to them, and one, the “ratlist,” has more than 1500 members with each having on average, 5-15 rats. And that doesn’t nearly account for all the U.S. families with pet rats.
One problem that we ratters find ourselves encountering on a regular basis is an almost immediate vet bill incurred due to the poor health of our pets acquired from pet stores who acquire their rats and mice from mass breeders. Because of improper care, housing, and handling, we find ourselves having to treat for pneumonia, parasites, and fungal infections at nearly the moment they walk into our homes.
We also worry about the welfare of our children as some parasitic and fungal diseases (which, with proper care, would never come to be) are communicable to our families (pinworms and ringworm, for example).
We believe that we are incurring these unnecessary veterinary and personal medical expenses because, currently there are no regulations or protections on how rats are handled, treated, housed, and transported. Rats are very robust animals, even moreso than cats or dogs, but because they are forced to spend the formative weeks of their lives in tiny feces-and-urine-coated containers which are in turn packed into poorly ventilated warehouses, it’s no surprise that they come home sick.
We, the rat community, would like to change that, so I am appealing to you for your help in this matter. We ask for your support in implementing specific regulations for the care of rats and mice (docket no. 98-106-4) as currently the only regulations in support of their care are filed under “Title 9: Subpart F". And those regulations are very rarely enforced because they are so “vague.”
We agree that the current regulations detailed by the NIH regarding the care of laboratory rats and mice, if incorporated and enforced, would be adequate in achieving this goal. With rat and mouse specific USDA protection we’re certain that we’ll have healthier rats because of cleaner living conditions, better care and treatment, and safer transportation. Please find it in your heart to help us to help our pet rats.
Sincerely,
[signature]
FirstName LastName
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