RE: Online Public Comments – Proposed Regulations for 2 VAC 5-105 (Regulations for the Inspection of Pet Shops Selling Dogs or Cats)

The Pet Advocacy Network works to protect and advance the interests of the responsible pet care community while advocating for responsible, family-owned pet shops across the country and the Commonwealth. We are a responsible community whose work begins and ends with the pet in mind. As such, we concur with the comments submitted by the VPAA, whose proposed amendments are below.

The proposed amendments are below.

Enclosure cleaning requirements

Removing a pet from the enclosure for ancillary cleaning and spot treatment raises huge cross-contamination concerns. This provision was intended to address the cleaning of cages at the Envigo/Cumberland facility that used high-pressure hoses – we use spray bottles and only apply to surface areas, not to the animals.

Power to revoke/suspend pet shop licenses

Currently, the animal care inspector is defined as a licensed veterinary technician appointed by the Commissioner of VDACS. While licensed veterinary technicians are qualified to identify potential hazards to animal welfare, they should not have the authority to revoke or suspend a shop's license or registration. A licensed veterinarian employed by the Commonwealth or the State Veterinarian should be the only individual allowed to revoke/suspend a shop's license. If a veterinary technician conducts an inspection, any potentially hazardous findings should be sent back to a licensed veterinarian or the State Veterinarian for evaluation.

Accommodating for offsite records

As most of our pet shops sell American Kennel Club puppies, which require documents to be saved for 5 years, and the record retention policy we are subject to by § 3.2-6512, utilizing offsite storage is necessary due to the volume of paperwork we are required to maintain.

The Pet Advocacy Network intends to continue to work with the legislature, VDACS, and industry stakeholders to satisfy all concerns and to ensure all Virginians can choose where they get their happy, healthy companion animals.

Alyssa Miller-Hurley

Senior Director of Government Affairs