Virginia Regulatory Town Hall
Department of Agriculture and Consumer Services
Department of Agriculture and Consumer Services
Regulations for the Inspection of Pet Shops Selling Dogs or Cats [2 VAC 5 ‑ 105]
Action Promulgate regulation required by Chapter 1284 of the 2020 Acts of Assembly
Stage Proposed
Comment Period Ended on 12/23/2022
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12/22/22  1:28 pm
Commenter: Virginia Pet Advocate Alliance

Proposed Regulations for 2 VAC 5-105

As members of the Virginia Pet Advocate Alliance, a group of responsible, family-owned pet shops across the Commonwealth, our goal is to ensure the health and welfare of our animals without unnecessarily burdensome requirements for our stores. Our proposed amendments are below:


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 technician are qualified to identify potential hazards to animal welfare, they should not have the authority to revoke or suspend a shops license or registration. A licensed veterinarian employed by the Commonwealth or the State Veterinarian should be the only individuals allowed to revoke/suspend a shops 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.


Enclosure cleaning requirements

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


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 due to 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. As most of our members are small, family-owned businesses, many have not yet been able to migrate all historical records to the cloud.


VPAA intends to continue to work with the legislature, VDACS, and industry stakeholders to satisfy all concerns and to ensure all Virginian’s can choose where they get their happy, healthy companion animals.

CommentID: 206774