Letter Addressing AAMC Concerns
with "Puppy Protection Bill"
October 22, 2001
The Honorable Tom Harkin
Chairman
Committee on Agriculture
636 Hart Senate Office Building
United States Senate
Washington, DC 20510
Dear Chairman Harkin:
The Association of American Medical Colleges (AAMC) has several
serious concerns with S. 1478, the "Puppy Protection
Act of 2001." Although the bill's stated purpose is to
control so-called "puppy mills" selling dogs to
the public as pets, the proposed changes also will affect
dogs being bred for research purposes and license revocation
requirements. Therefore, we ask that research animals and
research facilities be exempted from these provisions.
The AAMC represents the nation's 125 accredited medical schools,
nearly 400 major teaching hospitals, more than 100,000 faculty
in 98 professional and scientific societies, and 67,000 medical
students and 102,000 residents. More than half of the extramural
research funding awarded by the National Institutes of Health
goes to medical schools and their affiliated teaching hospitals.
Much of this research involves the use of research animals.
Consequently, the Association has a long history of involvement
in legislative and regulatory issues concerning the use of
animals in research.
The bill calls for engineering standards to be developed
based on the recommendations of animal welfare and behavior
experts for breeding, exercise and socialization of dogs.
These standards also would apply to research facilities and
Class A and B dealers that supply research dogs. There are
already in place carefully crafted, scientifically sound,
performance-based Animal Welfare Act (AWA) standards for the
care of research dogs, and these standards are different from
those that may be appropriate for pets. At the very least,
research animals should be exempt from the additional standards
for breeders of pets.
Also, the mandatory license revocation requirement you propose
for three AWA violations will apply to all exhibitors and
dealers, including research animal dealers. Further, it is
unclear whether this would apply to any violation of the AWA,
nor is it clear that it is limited to violations involving
dogs only. We believe this provision is confusing because
the violations are not defined in terms of severity. Currently,
the AWA and United States Department of Agriculture (USDA)
regulations do not distinguish between serious or animal life-threatening
violations and minor areas of noncompliance. USDA inspectors
can and do cite many small, technical violations that are
easily corrected. Therefore, a dealer could have its license
revoked for three minor violations even if immediate corrections
were made and the dealer was in full compliance with the law.
We believe this sanction is too severe and would discourage
inspectors from giving helpful feedback to licensees about
improving their programs.
While we recognize there are concerns with breeding programs
for dogs that will be sold as pets, we believe that any proposed
legislative changes to address these issues should not affect
animals being bred for scientific and medical research. Therefore,
we respectively request you consider the biomedical research
community's perspective and not forward any legislation that
would inadvertently interfere or inhibit sound medical and
scientific study. If you have any questions or if AAMC can
be of assistance, please feel free to contact Erica Froyd
at 202-828-0558 or Tony Mazzaschi at 202-828-0059. Thank you
for your consideration.
Sincerely,
Jordan J. Cohen, M.D.
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