The Dog Journal

USDA Today

As a USDA Compliance Coach, my first priority is to make sure that you understand the rules and regulations and are able to not only to bring your facility into compliance, but also stay in sustained compliance.

As you all know this takes effort on your part, requiring you to read and understand the regulations. Believe me, I know you can think of anything you would rather do! But being a USDA Professional Class A Companion Animal Breeder, you need to know the rules. Let’s consider the possibility that you are right on target and your facility is right. Then along comes a USDA Inspector to perform routine unannounced inspection.

Before we talk about the inspection, lets also consider some facts that you may or may not know but should consider. There has been a large percentage of Inspectors/VMO’s that have left USDA, been moved out of the field, or have been promoted.

This means that you may get a new/different inspector that you may not be familiar with, and that by itself can be a stressor. Toss in changes like the one announced by Dr. Betty Goldentyer, Deputy Administrator for APHIS’ Animal Care program that “as of August 1st, all noncompliances (those that directly impact the welfare of the animals, those that have indirect impacts on animals’ welfare, and even very minor noncompliances) will now be cited on inspection reports.” To put it simply, it looks like the “teachable moments” are now cancelled! Then there are the new record requirements found in 3.13 of the Animal Welfare Act or Blue Book.

It is easy to see that things could go wrong if you are not prepared. One of my favorite quotes is from Louis Pasteur, “Chance favors only the prepared mind” meaning that if you mentally prepare for a problem, you are far more likely to prevent that problem from overwhelming you, and you may even find that luck favors you because of your preparation.

Serving our industry as a Compliance Coach can sometimes be challenging because people do not like change unless it’s their idea. They like it even less if comes from an authority like the USDA. So, the best way around the uncomfortableness of an inspection, and to reduce the chance of NCI’s is quite frankly to be prepared and educated.

Industry standards continue to change, and this puts pressure on our breeders. While these changes are good, and needed in some cases, it is still change. A Professional Class A Dealer (Breeder) needs to know what to expect from USDA and needs to understand that USDA has expectations of them.

 So, what I would like each licensed breeder to do, is to look around at what you have accomplished, remember the journey of how you got here, and know that you can handle these changes because you’ve been handling changes throughout your whole breeding career. A truly prepared breeder has no fear of USDA or state agencies, this is because a prepared breeder knows the regulations just as well as does the inspector. Remember, an inspection is simply an open book test. You have all the answers in front of you before they ask the questions, you just have to find them!

Your Dogs Medical Records Requirements 3.13

A licensee with dogs must: 

  • Keep copies of medical records for dogs, and 
  • Make the records available for APHIS inspection 
  • Medical records for dogs must include Identity of each animal including:
  • Identifying marks 
  • Tattoos 
  • Tags 
  • Breed 
  • Sex 
  • Age 

If a medical problem is identified (such as disease, injury, or illness), the following information is required in the dog’s medical record:

  • Date the problem was identified 
  • Description of the problem 
  • Examination findings 
  • Test results 
  • Plan for treatment and care 
  • Treatment procedures performed, when appropriate 
  • Names of all vaccines administered and the date(s) of administration 
  • Names of any treatment administered and the date(s) of administration 
  • Dates and findings/results of all: 
  • Screening 
  • Routine or other required or recommended tests 
  • Examinations 
  • Medical records for dogs must be kept and maintained: 
  • For at least one year after the dog is euthanized or disposed of, and 
  • For any period more than 1 year as necessary to comply with Federal, State, or local law 

The following records requiring veterinary approval are required for dogs and cats, when applicable:

  • Exercise plan for dogs [3.8] 
  • Attending veterinarian approved exercise exemption [3.8(d)(1)] 
  • Health certificate for transport [2.78(a)] 

 

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