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HomeMy WebLinkAboutCOM 1145.125 2012-2014CI L PIJAC Col 20I4 NOW ! 8 F%11 t- 33 Testimony of the Pet Industry Joint Advisory Council On County of Hawai'i Bill No. 318 An Ordinance Amending Chapter 4 November 15, 2014 To Whom It May Concern: The following comments are submitted on behalf of the Pet Industry Joint Advisory Council (PIJAC), the world's largest pet trade association representing the interests of all segments of the pet industry. For more than 40years, PIJAC has promoted best practices for handling and care of live animals. For many decades, PIJAC has been engaged in all aspects of regulating the movement of live animals via all modes of transport. PIJAC has actively participated in the deliberations of the International Air Transport Association's Live Animals and Perishables Board leading to the publication of the IATA Live Animal Regulations, the globally accepted standards for transporting animals of all types. I chair the IATA Live Animal Board's Advisory Committee that is responsible for ensuring that the Regulations' standards for preparing and shipping live animals. reflect up-to-date animal welfare and veterinary husbandry practices applicable to the preparation/conditioning of the animals pre -shipment, shipping containers, and handling during transport. Portions of Federal regulations as well as the Convention on International Trade in Endangered Species (CITES) mandate compliance with the IATA Regulations when shipping covered species. The preparation and shipping of live animals is not conducted in a vacuum. Contrary to some beliefs of anti -trade activists supporting Bill 318, neither shippers nor airlines dealing with live animal transport prosper economically by transporting sick, dying or dead animals. As a preliminary comment, we find it most interesting that the subject Bill targets only certain aspects of activities involving aquatic life to wit aquarium life destined only for aquarim n use outside of the county. Such discriminatory treatment of a highly, if not the most highly regulated Hawaiian in -shore fishery raises interesting questions of the true intent of a bill ostensibly designed to ensure humane care when in fact it is designed to shut down interstate and international trade involving fish destined for "aquarium use" under the guise of "animal welfare." Such rank discrimination raises interesting questions why similar restrictions are not imposed upon all forms of aquatic activities, both State and non -State regulated fisheries! Good governance is made of sterner stuff! P/AWEX ctog- o6 PET INDUSTRY JOINT ADVISORY COUNCIL 1146 19" Street, N.W., Suite 350 Washington, DC 20036 Tel: 202-452-1525 Fax: 202-452-1516 CHAIRMAN Ken Oh W F Young, Inc., East Longmeadow, MA FIRST VICE-CHAIRMAN Jeff Sutherland Animal Supply Company, Federal Way, WA SECOND VICE-CHAIRMAN Greg Cyr Central Garden and Pet, Walnut Creek, CA SECRETARYITREASURER Andy Ponte United Pet Group, Cincinnati, OH DIRECTORS Ryan Boyle The Hunte Corporation, Goodman, MO Tom Edling, DVM Petco Animal Supplies, San Diego, CA Bruce Flantzer MiracieCorp Inc., Dayton, OH Chris Fleming Pinnacle Pet, Neosho, MO Heather Govea Natural Balance Pet Foods, Burbank, CA Rolf Hagen Rolf C. Hagen Inc., Bale D'urie, Quebec John Mack, Reptiles By Mack Xenia, OH Michael Peterson The Pet Group, Carlsbad, CA Laura 'Peach" Reid Fish Mart Inc., West Haven, CT Jim Seidewand Pet World, Inc., Rochester, NY Joe Watson Petland Inc., Chillicothe, OH Marcie Whichard Petco Animal Supplies Inc., San Diego, CA ASSOCIATION REPRESENTATIVES Jim Boschee (WPA) Calabasas, CA Kevin Fick (APPA) Woridwise, San Rafael, CA Steve King (PIDA) Pet Industry Distributors Assoc., Abingdon, MD Sandra Moore (FTFFA) Segrest Farms, Gibsonton, FL PAST CHAIRMEN James Heim Walnut Creek, CA Frank Koch Pacoima, CA Allan Levey New York City, NY Alexandre Perrinelle Los Angeles, CA Elywn Segrest Gibsonton, FL PRESIDENT/CEO Edwin Sayres � f riSL NUV 18 2014 Quite simply there are no science -based studies substantiating a One Gallon rule or limiting the withholding of food for no more than 24 hours. IATA's guidelines covering feeding and watering are based on the documented premise that feeding and watering requirements must vary by species as well as by individual specimens . within a species, mainly due to age, size, pre -shipment conditioning, length of haul, etc. Fundamental to IATA's approach, therefore, is shippers have the responsibility of utilizing the generally accepted animal husbandry and veterinary care practices when preparing their animals for shipment via air. IATA's Regulations provide that shippers are to responsibly pack the specimens to survive for 48 hours in transit. In order to meet the IATA 48-hour rule, withholding food is essential to clear the gut of food to minimize the fouling of transport containers. Absent such pre -shipment protocols, the fish could be subjected to unacceptable toxic ammonia levels or other wastes resulting in poor water quality, which in turn is an undesirable stressor that could lead to death or serious morbidity. That is why customary practices as indicated by the Association of Zoos and Aquariums, as well as information provided below, notes that a "2-10 day fast is routinely done as a matter of professional practice." Such pre -shipment conditioning reflects acceptable veterinary husbandry practices. For example, the Convention on International Trade in Endangered Species of Wild Fauna and Flora (CITES) Transport Guidelines' at page 73 provided, in pertinent part, that fish shipments should be packed "in order to minimize pollution of the water, fishes should not be fed for 24 hours prior to shipment." In crafting their Guidelines, CITES relied upon not only the IATA LARs of 1980, but also recommendations from leading researchers from around the globe from a number of zoos, aquariums, research institutions, and humane societies. CITES, at its Conference of the Parties in March 2013, adopted a resolution containing language applying IATA LARs along with several special rule3 unique to ground transport when transporting CITES -listed species by air or surface transport modes. The IATA LARs have long recognized that the withholding of food prior to shipment of aquatic organisms is a globally accepted practice not only within the ornamental fish trade, but also in the live food fish trade. The withholding of food prior to transport decreases the amount of excreta from the fish, reduces the metabolic rates, and thus reduces water pollution; pollution that could counter IATA's 48-hour in -transit rule for tropical fish shipments. Withholding food also has been shown to reduce stress responses to handling and thus reduces unnecessary loss during packaging and transport. The IATA guidelines are based on not only years of empirical experience, but also from the literature. A 2010 publication of the University of Florida recommended "Withholding food from the [tropical] fish for at least 24 hours just before shipment allows them to purge their digestive tracts, which greatly reduces the buildup of wastes during shipping. It also takes longer for larger fish to completely empty their guts. " Watson, Craig A., Shipping Fish in Boxes, SRAC Publication No. 3903 (20 1 0)(Emphasis 1 In recent years, CITES has adopted the IATA LARs as a substitute for its 1981 Guidelines. supplied) Approximately 10 years earlier at a University of Alaska Sea Grant Conference, it was reported that "All live seafood items should be starved for at least 24 hours before they are packed to avoid the inevitable occurrence of vomiting undigested food... " Post, Brian C., Rice, Allison A., et. al. editors, Marketing and Shipping of Live Aquatic Products, Proceedings of the Second International Conference and Exhibition, University of Alaska Sea Grant Program, Seattle, Washington, page 197 (1999). (Emphasis supplied) And from the NOAA website, one can find the APEC statement at page 18: "Diurnal rhythms also affect oxygen demand. Handling and packing procedures should be designed to keep metabolic rates at a low level. In most cases, this can be accomplished by reducing temperature and eliminating feeding for several days prior to shipping. The optimal time to cease feeding varies depending upon the species. Feed reduction schemes should consider product weight loss in order to ensure that the product condition remains prime. " Air Shipment of Live and Fresh & Seafood Guidelines, APEC Fisheries Working Group, January 1999. (Emphasis supplied) In an Hawaii based report on shipping ornamentals, Drs. Cole, Tamaru, Bailey, Brown, and Ako found: "Feeding should be withheld for a minimum of two days and up to five days, depending on species, " Cole, B., Tamaru, C., Bailey, R., Brown, C., and Ako, H., Shipping Practices in the Ornamental Fish Industry; Center for Tropical and Subtropical Aquaculture Publication Number 131, (February 1999: Hawaii NOAA Sea -Grant project) (Emphasis supplied) Thus, it is clear from the literature that a specific 24-hour limitation is not sacrosanct. As one would expect, the feeding requirements will vary not only among species, but also with specimens within a species depending on age, size, pre -transport conditioning, similar to what human primates experience. Quite simply, shipping fish without fasting appropriate for the species can be dangerous and run counter to the desired mandatory standards being proposed. As noted in numerous papers regarding the preparation and shipment of fish destined for "aquarium use," no one has presented any science -based data substantiating the appropriateness of a One Fish/One Gallon minimum requirement when shipping fish destined for the aquarium trade, let alone any other use such as for food fish or non-commercial activities as exempted in the proposed Bill. While PIJAC supports humane transport standards, such standards must be non-discriminatory, science -based, and not a knee jerk reaction to activists attempting to misuse a county ordinance to effectively ban a state regulated industry that they historically have attempted to ban. The underlying justification for the Ordinance's "findings" coupled with misinformation floating around the Internet regarding unsubstantiated "loss," "the normal lifespan of aquatic life, " conflicting statements as well as reliance on several articles which deal with the Philippines or other remote fisheries, not the Hawaiian experience, reflects multi -faceted analytical infirmities hardly supportive of the proposed Ordinance. It should not be overlooked that the Hawaiian aquarium fishery is a long-established, well -regulated industry by the State's Department of Land and Natural Resources.2 Thank you for the opportunity to submit our comments with respect to the proposed Ordinance. As an attorney having been intimately involved with the aquarium trade since the late 1960s3, 1 look forward to working with the Council to ensure that all regulated fisheries are managed and regulated pursuant to the International Union for the Conservation of Nature's (IUCN) Principles and Guidelines for the Sustainable Use of Biodiversity by promoting both conservation and livelihoods du-otach enhancing equitable and sustainable use of wild species and their associated ecosystems. Respectfully submitted Pet Industry Joint Advisory Council N. Marshall Meyers Senior Advisor ' The most recent round of amendments to the State's West Hawai'i fishery rules provide a number of improvements to the regulatory mechanism. These reflect the results of years of research, committee meetings and community discussions. As before, permit holders are required to "to keep all aquatic life taken under the permit alive and in reasonable health" as well as "maintain the proper operation offacilities designed to keep fish alive and in reasonable health. " Over the years, my practice has involved representing the largest all -cargo airline, The Flying Tiger Line (now FedEx), as well as the pet industry, and a number of zoos, public aquariums, biomedical facilities and individual shippers.