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Home My WebLink AboutCOM 0140.121 2014-2016PIJAC PET INDUSTRY JOINT ADVISORY COUNCIL 1146'910 Street, IN,", Suite 356 Washington, DO 20036 ®I Tel 202-452-1525 `® FSH: 202-452-1516 TESTIMONY OF THE PET INDUSTRY JOINT ADVISORY COUNCIL CHAIRMAN FOR CONSIDERATION OF THE IIAWAII COUNTY COUNCIL Red 05 W FYoung. Inc.. East Longmeaeov,, MA IN OPPOSITION TO Bill 318 FIRST VICE-CHAIRMAN To be heard February 17th at 1:30 PM Jeff Sutherland Animal supply company. Federal Way, WA February 12, 2015 SECOND VICE-CHAIRMAN Greg Cyr Central Garden end Pel. walnut Creek, CA 'fhe following testimony is presented on behalf of the Pet Industry Joint Advisory Council SECRETARYOREASURER (I'IJAC) and its membership in opposition to Bill 318, defining certain activities involving Andy Ppme Group, ancinnali, OH the collation of fish as animal cruelty. We appreciate the opportunity to submit our United Pet Comments before the County Council RyRrumo.Rs The Hume Corporation, Goodman, Mo PIJAC is the world's largest pet trade association representing the interests of all segments of r.a Edr,, the pet industry. PIJAC's membership includes member associations, organizations, and Pam. Animal S.ppras. San Dingo, CA corporations as well as individuals involved in the commercial and hobby pet and aquarium Bruce Flamer Cover. OF trade. More specifically, we represent the interest of live animal retailers, Mlraelecora Inc.. I mparters/exporters) breeders, product manufacturers, wholesale distributors, and hobbyists. Bide Fleming Parable pat Nensno. MO For more than 40 years, PUAC has promoted best practices for handling and care of live Gave. roamer GNorvale aea vece pet F..aF, euNank. cn animals. For many decades, PIJAC has been engaged in legislation, regulation and best holt Hagan associated with the movement of live animals via all modes of transport. PIJAC Rolf c. He,.,, mg., Safe oun., o.edec practices teas actively participated in the deliberations of the Intranational Air Transport As'sociation's John Mack. Reptiles By Mack Live Animals and Perishables Board leading to the publication of the IATA Live Animals xama. off Regulations, the globally accepted transport standards for animals of all types. PIJAC's Michael GrouPocansdad, CA Grouprach' Car to the IATA Board chairs IATA's Live Animal Advisory Committee and has TherPet representative several airlines as well as animal slippers for over 40 years and is well versed in nen Man lase., West Haven CT read epresented all aspects ofair transportation of live animals. it. suedewand Pet World Inc., RWtesid, NY A review of Bill 318 raises a number of issues which are inconsistent with acceptable animal Joe Wain., husbandry practices and, if adopted as dratted, would achieve tate opposite result of the pnlland In, endr—mh., OR proponents' objectives: the unnecessary stress and death of transported animals. Marcie Wmcherd Palo. Animal Supplies Inc., San Diego. CA 'I he preparation and shipping of live animals is not Conducted in a vacuuln. Contrary to ASSOCIATION REPRESENTATIVES .fm Beechen (Weal some beliefs, shippers involved with live animal transportation do not prosper economically converses, CA by transporting sick, dying or dead animals. The withholding of food prior to shipment is in Ing—Fmk (APPA) the best interest of the fish and does not constitute animal cruelty. W.rmwise, son Rafael, CA Steve Ring (PIOA) Shippers utilize customary and generally acceptable husbandry and veterinary care practices Pet Industry olsm ided, Aemc., Admgden. Mn when preparing the animals for transport. The terms and conditions governing the Sarva Made(FrFFA) FL acceptance and carriage of live animal have evolved aver the years to the current stale Found Segreel Farms, Gdamdon, III the 41St Edition of InternationalAir Transport Association (]ATA)'s Live Animals CHAIRMEN James Helm Regulations (LARs) (2015), which contains detailed criteria, recommendations and walnut Croak CA guidelines in a 400 -plus page document. The information found in the LAR; reflects Frank Fod transport standards developed over decades of experience in transporting hundreds of PacoimaCA millions of live animal shipments. The IATA LARs are the global standard adopted by AllenLevey ev, hundreds of airlines, they are incorporated in national laws, and are prescribed by one or Nava York City Nr Alexandre pay Nene more United Nations Treaties. Los articles, CA Divan Segrest Gme.mon, FL 17,1 PRESIDENT/CEO emm: NO. crux, Cannes Ref. To: /iIW Ref. DateFEBFEB 1 IA'IA'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, pc - shipment conditioning, length of haul, ele. 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 rate, 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 infomtation 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 shipmenC' In crafting their Guidelines, CITES relied upon not only the IAPA 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 recon sized that the withholding of food prior to shipment of aquatic organisms is a globally accepted practice not only widrin the ornamental fish trade, but also in the live food fish trade. The withholding of food prior to transport decreases the amount of excreta front 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 TATA guidelines are based on not only years of empirical experience, but also upon relevant literature. A 2010 publication by the University of Florida recommended "IAit!! !dine food from the Itrooicall f 1 far at least 24 boars just before shipment allows then, to purge their digestive n'aco, which greatly reduces the buildup of wastes during shipping. It also takes longer for larger fish to completely ernpry their gifts. " 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, at 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 Gom the NOAA website, one can find the APEC statement at page I8: 'Diurnal rhytluns also affect oxygen demanQ Handling and- packing procedures shin ld be designed to ked in belie rates at a low level. In most cases, this can be accomplished by reducing lemperanpe and f rr g f d g fo� 'e 'al d v prior to shipping. The optimal time to cease feeding varies d ep ulirg upon the species Feed reduction schemes should consider product weight loss in order to ensure that the product condition remains prince." Air Shipment of Live and Fresh & Seafood Guidelines, APEC Fisheries Working Group, January 1999. (Emphasis supplied) ]it an I luwaii based report on shipping ornamentals, Urs. Cole, Tamara, Bailey, Brown, and Ako found In recent years, CITES has adopted the IATA LARs as substitute for its 1981 Guidelines. ' Feedin>, should he withheld %r a minim,um ofnao days and uD tolive days'. depending on species, "Colo, B., Jammu. C., Bailey, R., Brown, C., and Ako, H., Shipping Practices in the Ornamental Fish Indushy, Center for Tropical and Subtropical Aquaculture Publication Number 131, (February 1999: Hawaii NOAH Sea-Gran( 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. Tao 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 Slate University study by Emily Monday —"The Effects of Venting and Decompression on Mortality and Sublethal Effects in Yellow Tangs (Zebrasoma flaveseens) Caught for the West Hawaii Aquarium Trade'— found that the practices of the Ilawaii 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 orventing 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 trimming 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, m defeat, Bill 318. '['hank you for your consideration. Robert A. Likin Director of Government Affairs Pet Industry Joint Advisory Council