HomeMy WebLinkAboutCOM 0140.078 2014-2016r/AWXS c.
P 318'
From: Bob Likins <bob@pijac.org>
Sent: Friday, February 13, 2015 3:59 AM
To: Council Testimony
Subject: PIJAC Testimony on Bill 318 _
Attachments: Bill 318 (final).pdfJ
Sir or Ma'am,
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Please accept the attached testimony for the Hawaii County Council on Bill 318 from the Pet Industry JoitiVAdvisory.
Council (PIJAC).
Sincerely,
Robert Likins
Robert Likins III
Director of Government Affairs
Pet Industry Joint Advisory Council (PIJAC)
1146 191h Street NW, Suite 350
Washington DC 20036
202-452-1525 x1070
bob@piiac.org
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PIJAC
PET INDUSTRY JOINT
ADVISORY COUNCIL
1146 19°i Street, N.W., Suite 350
® ®
Washington, DC 20036
Tel: 202-452-1525
Fax: 202-452-1516
TESTIMONY OF THE PET INDUSTRY JOINT ADVISORY COUNCIL
CHAIRMAN
FOR CONSIDERATION OF THE HAWAII COUNTY COUNCIL
Ken On
W F Young, Inc., East Longmeadow, MA
IN OPPOSITION TO Bill 318
To be heard February 17th at 1:30 PM
FIRST VICE-CHAIRMAN
Jeff Sutherland
Animal Supply Company, Federal Way, WA
February 12, 2015
SECOND VICE-CHAIRMAN
Greg Cyr
Central Garden and Pel, Walnut Creek, CA
The following testimony is presented on behalf of the Pet Industry Joint Advisory Council
SECRETARYITREASURER
(PIJAC) and its membership in opposition to Bill 318, defining certain activities involving
Andy Ponte
the collection of fish as animal cruelty. We appreciate the opportunity to submit our
United Pet Group, Cincinnati, OH
comments before the County Council.
DIRECTORS
Ryan Boyle
The Hunte Corporation, Goodman, MO
PIJAC is the world's largest pet trade association representing the interests of all segments of
Tom Edling
the pet industry. PIJAC's membership includes member associations, organizations, and
Petco Animal Supplies, San Diego, CA
corporations as well as individuals involved in the commercial and. hobby pet and aquarium
Bruce Flantzer
trade. More specifically, we represent the interest of live animal retailers,
MiracleCorp Inc., Dayton, OH
importers/exporters/ breeders, product manufacturers, wholesale distributors, and hobbyists.
Chris
n�lePet, Neosho, MO
For more than 40 years, PIJAC has promoted best practices for handling and care of live
Heather Gove2
al Balance Pet Foods, Burbank, CA
animals. For many decades, PIJAC has been engaged in legislation, regulation and best
Rolf Hagen
practices associated with the movement of live animals via all modes of transport. PIJAC
Rolf C. Hagen Inc., Bale D'urfe, Quebec
has actively participated in the deliberations of the International Air Transport Association's
John Mack. Reptiles By Mack
Live Animals and Perishables Board leading to the publication of the IATA Live Animals
Xenia, OH
Regulations, the globally accepted transport standards for animals of all types. PIJAC's
Michael Peterson
representative to the IATA Board chairs IATA's Live Animal Advisory Committee and has
The Pet Group, Carlsbad, CA
represented several airlines as well as animal shippers for over 40 years and is well versed in
Laura'Peach" Reid
Fish Mart Inc., West Haven, CT
all aspects of air transportation of live animals.
Jim Seidewand
Pet World, Inc., Rochester, NY
A review of Bill 318 raises a number of issues which are inconsistent with acceptable animal
Joe Watson
husbandrypractices and, if adopted as drafted, would achieve the opposite result of the
Petland Inc., Chillicothe, OH
proponents' ,objectives: the unnecessary stress and death of transported animals.
Marcie Wnichard
Petco Animal Supplies Inc., San Diego, CA
The preparation and shipping of live animals is not conducted in a vacuum. Contrary to
ASSOCIATION REPRESENTATIVES
some beliefs, shippers involved with live animal transportation do not prosper economically
Jim Boschee (W PA)
Calabasas, CA
by transporting sick, dying or dead animals. The withholding of food prior to shipment is in
Kevin Fick (APPA)
the best interest of the fish and does not constitute animal cruelty.
Worldwise, San Rafael, CA
Steve King (PIDA)
Shippers utilize customary and generally acceptable husbandry and veterinary care practices
Pet Industry Distributors Assoc., Abingdon, MD
when preparing the animals for transport. The terms and conditions governing the
Sandra Moore (FTFFA)
acceptance and carriage of live animal have evolved over the years to the current state found
Segrest Farms, Gibsonton, FL
in the 41st Edition of International Air Transport Association (IATA)'s Live Animals
AIRMEN
PAST James Heim
Regulations (LARS) (2015), which contains detailed criteria, recommendations and
Walnut Creek, CA
guidelines in a 400 -plus page document. The information found in the LARS reflects
Frank Koch
transport standards developed over decades of experience in transporting hundreds of
Pacoima, CA
millions of live animal shipments. The IATA LARS are the global standard adopted by
Allan Levey
hundreds of airlines, they are incorporated in national laws, and are prescribed by one or
New York City, NY
more United Nations Treaties.
Alexandre Perrinelle
Los Angeles, CA
Elywn Segrest
Gibsonton, FL
PRESIDENTICEO
Edwin Sayres
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.
In some circumstances, IATA provides species-specific guidelines. In other situations, which cover thousands of species
of all ages, sizes and shipping conditions (i.e. bulk shipments in sealed containers versus single specimen shipments or
shipments accompanied by attendants), IATA's guidelines leave it to the shipper to apply appropriate pre -conditioning.
Inasmuch as the term "tropical fish" generically categorizes thousands of species, IATA provides 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 in its testimony, as well as
information provided below, notes that a "2-10 day fast is routinely done as a matter of professional practice."
For example, the Convention on International Trade in Endangered Species of Wild Fauna and Flora (CITES) Transport
Guidelines' at page 73 provide, 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 a Conference of the Parties in March 2013,
adopted a resolution containing language applying IATA LARs along with several special rules unique to ground transport
when transporting CITES -listed species.
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 upon relevant literature. A 2010
publication by the University of Florida recommended
"Withholding food from the ftropicall 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 (2010)(Emphasis supplied)
Approximately 10 years earlier at a University of Alaska Sea Grant Conference, it was reported that all live seafood items
should fast 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 packirt
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:
' In recent years, CITES has adopted the IATA LARs as a substitute for its 1981 Guidelines.
"Feediniz should be withheld for a inininnun of tivo 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 NOAH Sea -Grant project) (Emphasis
supplied)
As one would expect, the feeding and watering requirements vary not only among species, but also with specimens within
a species depending on age, size and pre -transport conditioning, as they would among different humans.
Too often animal rights activists have been successful because they can make something sound much more dramatic than
it is. When it comes to "piercing swim bladders," it is done to protect the health of the fish, and a 2012 Washington State
University study by Emily Munday — "The Effects of Venting and Decompression on Mortality and Sublethal Effects in
Yellow Tangs (Zebrasoma flavescens) Caught for the West Hawaii Aquarium Trade" — found that the practices of the
Hawaii fish exporters did not cause any mortality in Yellow Tangs received by the researcher and held for the duration of
the 6 month study – and ongoing observation. Although researchers expected to find higher mortality rates in vented fish,
they did not. Their report found that "Though animal rights groups in Hawaii criticize venting, we did not find that it
caused mortality or sublethal injuries in Yellow Tang. Banning venting may increase mortality rates if fishers
implemented ascent without decompression. While opponents of venting have suggested that slow decompression be used
instead, the time required to properly decompress these fish is economically prohibitive and impractical for fishers to
implement."
Similarly, cutting the fin or spine sounds traumatic. Trimming tail spines (fins are not trimmed) is actually the equivalent
of trimining your nails, and keeps them from puncturing the shipping bags. There are no published reports or scientific
studies readily found that support the proposed ban on the sale of fishes with clipped fins. If data exists to contradict the
experience of fishers and those in the trade who liken the practice to cutting one's toenails, it has yet to be presented.
The most inexplicable requirement in Bill 318 is that shippers hold fish or aquatic life in a gallon of water. The dictate of
one gallon per fish seems specific enough that one would assume that it was derived through scientific analysis. If it was,
however, there is no mention of the source. In fact, requiring one gallon of water per fish is apparently completely
arbitrary and there are absolutely no science -based studies supporting such a requirement.
The aquarium trade has decades of experience in transporting fish responsibly, and has a spectacular record of doing so
successfully. Imposing these arbitrary requirements with no scientific basis to justify them can only have a detrimental
effect on the fish. PIJAC strongly opposes Bill 318. We respectfully request that the Hawaii County Council side with
science over unnecessary solutions to non-existent problems. We ask that the council decline to take up, or defeat, Bill
318.
Thank you for your consideration.
Robert A. Likin
Director of Government Affairs
Pet Industry Joint Advisory Council