We now have an OPPORTUNITY until early October to tackle a number of
the things that lead over and over again to complaints on the FML and
elsewhere.  Right now we have the chance to take the need for ferret-
specific regulations for farms, distributors, and transporters to the
next step beyond the petition level.
 
We can make an impact by pressing for changes to the USDA regulations.
Because so many of you let the USDA know that farms, distributors, and
transporters are simply not doing their jobs safely enough for ferrets
we have reached the second step where they are requesting input to see
if people want them to continue.
 
The thing about changing USDA regulations is that their established and
required protocol requires long waits and then a lot of rapid action
within deadlines by all of us who want improvements.
 
So, that is exactly what we need to do to reach our goals.  If we succeed
then in the next step they will consider specifics.
 
The USDA does NOT regulate small breeders who do not sell to retail
stores; other agencies oversee those.  Anyone who is not currently under
USDA regulation will not be under USDA regulation.  This will have no
effect on small breeders who sell directly to their ferrets purchasers.
They are under their own states' regulations.
 
Personally, I am sending four copies of my letter by snailmail because I
think that will have the greatest impact.  Others will prefer to use the
edocket option.
 
Please, see this public site and POLITELY let them know that you want
improvements made to the standards for ALL FARMS, ALL DISTRIBUTORS,
AND ALL TRANSPORTERS USED BY THOSE FARMS AND DISTRIBUTORS:
http://www.aphis.usda.gov/ppd/rad/webrepor.html
and click open
Recent Documents
OR
http://www.aphis.usda.gov/ppd/rad/webrepor/all.html
and open
 
> Animal Welfare; Standards for Ferrets
> Docket No. 04-088-1
> Notice of petition and request for comments
> 9 CFR Part 3
> Published August 5, 2005
> 70 FR 45322-45323
> Text | PDF | EDOCKET
 
and then clink on any of the three links to read more and to file an
edocket.
 
YOU CAN MAKE A DIFFERENCE.  YOU CAN HELP END THE FRUSTRATION WE ALL
SUFFER ABOUT SICK, YOUNG KITS, AND NEEDLESS SUFFERING AND DEATH.
Please, write your polite and encouraging letter to change these
industries for the better!
 
Here is the letter I sent:
 
 Docket No. 04-088-1, Regulatory Analysis and Development, PPD
 APHIS, Station 3C71
 4700 River Road, Unit 118
 Riverdale, Maryland 20737-1238
 
 Dear APHIS Animal Care Experts,
 
 I am so very grateful that the USDA is now seeking input on some of
 the ways that current regulations fail to protect ferrets, Docket
 04-088-1.
 
 There is barely a month on any major ferret electronic list when
 someone does not seek help with a kit who was transported and sold
 too young.  This was not always the case.  Before ferrets became so
 popular the typical pet store ferrets were at least 8 weeks of age, a
 safe age for transportation and sale of healthy kits.  This is not
 just personal recollection.  I have heard it from others, including
 those at one of the major farms who told me that competition forced
 them to lower their shipping ages from 8 weeks to 6 weeks.
 
 Eight weeks also is an easy age to check because when a kit is 8
 weeks of age the conical adult canine teeth are replacing the
 needlelike kit canines then, so all one has to do is to look for
 adult shape canine teeth.  (At 50 and 53 days approximately they also
 erupt first molars, both mandibular and maxillary, meaning that they
 can deal dentally with the sort of diet a pet store will provide.)
 
 Just as it is financially feasible for the ferret farms to sell kits
 at no younger than 8 weeks of age, it is also not an economic burden
 upon pet stores.  Petsmart has been selling ferrets at no younger
 than 12 weeks of age since last year.
 
 I wind up reading of too many situations in which kits were so
 undeveloped and unready for weaning that they could not properly eat
 kibble, or they wound up with painful rectal prolapses.
 
 We ourselves have cared for such kits.  One, aged by later dental
 eruption, fit in the palm of my hand, and I have tiny hands for a
 woman.  By dental age obtained later she was barely 5 weeks old when
 she joined our family.  Our vet had to help us with a milk replacer
 that we gave as well as food slurry.  She would keep entering my
 clothing not only for comfort but to try to suckle from me -- a very
 unusual behavior but one which emphasizes that she was among those
 who were sold too young.  Thankfully, she was not among those who
 develop serious health problems from being sold so young, but she did
 require special care.
 
 Another well known problem is that of poor temperature control during
 transport.  Ferret kits are highly vulnerable not only to rapidly
 induced hunger and dehydration, but to temperature extremes,
 especially high temperatures.  In fact, ferrets of any age have
 difficulty with high temperatures.  Several times already there have
 been news stories, or internet rescue conversations about unacclimated
 ferrets who were exposed to temperatures of over 80'F for too long who
 died or suffered brain damage at airports or elsewhere in transit,
 sometimes also acquiring kidney damage when dehydration also occurred.
 This would be so easily avoided if people simply understood the
 conditions ferrets need to survive.
 
 With the large increase in ferret popularity far too many people have
 tried to cash in without knowing what they were doing.  This has led
 to a number of products which are inappropriate to ferrets (and out
 of your control) as well as many people breeding without any idea
 what they are doing in terms of health and longevity.  Some of those
 include some farms, and farms are the sellers who are controlled by
 USDA regulations.  One of the bad farms sold several years ago.
 Reports from people I trust were that their cages had flooring that
 was wire with openings too large for safety, but that is not all.
 They chose that size of wiring because they were having pigs walk
 below the cages and eat dropped feces and food as a way to reduce
 their labor.  I don't have to tell you what sort of zoonotic problems
 can arise when three species prone to influenza (humans, ferrets, and
 pigs) live in that sort of close contact.  Just as with those in
 charge of transport knowing too little about ferret health needs, so,
 too, do some farms know too little, or care too little.
 
 I would like to see a group of new ferret-specific regulations which
 take into account the ways that ferrets differ from dogs and cats,
 and I strongly think that the best regulations would be designed by
 ferret veterinarians.
 
 Thank you so very much again for all of your hard work!  The problems
 which exist are not at all caused by only one farm, one transporter,
 or one distributor.  They are encountered across the board.  In some
 cases, as with the mid sized farms which first began selling at young
 ages the choice was their own and ferret health was ignored.  In
 other cases other farms, including a large one, felt pressured to
 reduce their ages of sale due to the competitive pressure created by
 the first group.  Many other times the harm to ferrets comes just
 from ignorance on the parts of farms, distributors, or transporters.
 These are only three of the risks that exist currently or recently
 existed.  Ferret-specific regulations would go a huge way toward
 correcting such difficulties.
 
 With gratitude,
[Posted in FML issue 4964]