Regulatory Activity - 2012 Archive
Health Certification for pets and horses traveling to Canada
If your clients are traveling to Canada for vacation, make sure you provide the correct export documents for the pets and horses that will travel with them.
The Canadian Food Inspection Agency (CFIA) establishes importation requirements for animals entering Canada. USDA-accredited veterinarians need to be aware that requirements for certification of animals for movement into Canada may change due to specific disease concerns. Always verify current requirements to be sure all documents are complete and provide the required certification.
The USDA Area Office in Tumwater has two staff members available to help with International Health Certificates, Ms. Kristine Kraig and Ms. Lilly Nieves. The Area Office’s contact information is—
USDA APHIS VS Area Office for AK/OR/WA
1550 Irving Street, Suite 100
Tumwater, WA 98512
Main office phone 1-360-753-9430
Hours 7:30 am to 4 pm, Monday through Friday
You will find general information about preparation of International Health Certificates for a wide range of animal species and animal products on the USDA Area Office website.
Sources for further information—
Canadian Food Inspection Agency website
Dogs and cats—
CFIA only requires a valid rabies vaccination certificate for dogs and cats entering Canada with their owners. Dogs and cats must have a current rabies vaccination if they are over 3 months old. The rabies certificate should clearly identify the pet (breed, color, weight, etc.) and give details on the rabies vaccine used (date given, trade name, serial number and whether the vaccine used was valid for one or three years).
If pets are younger than 3 months of age, it is recommended that a Health Certificate, which states that the animal is too young for rabies vaccination, accompany the animal.
It is also recommended that owners with pets traveling to Canada have a valid Health Certificate for their pet, which documents the rabies vaccination. Customs agents from the Canada Border Services Agency may ask to see a valid Health Certificate. There have been instances of pets without Health Certificates being refused entry into Canada.
You can issue a Health Certificate for international travel if you are licensed and USDA-accredited. The Small Animal Health Certificate does not need to be endorsed by USDA.
Proper form for dogs and cats—
- Washington State Small Animal Health Certificate form AGR 300-3008 or
- USDA’s Small Animal Health Certificate form VS-7001
If the client is considering travel by air, the International Transport Association restricts air travel to dogs 8 weeks of age or older. Whenever a pet travels by air, the owner should consult the specific airline carrier for additional information and requirements.
If dogs are not accompanied by their owners when transported into Canada, an export Health Certificate is required for entry. The required certificate can be found online on the USDA website. Physical examination by the veterinarian issuing the certificate must be completed within 36 hours of arrival in Canada.
The Centers for Disease Control and Prevention (CDC) regulates re-entry of US-origin dogs and cats into the US. Requirements for pets entering the US are on the CDC website. Pets can generally return to the US from Canada provided they have a current rabies vaccination certificate. However, if the owner and pets return by air, the airline may require a current Health Certificate. The pet owner should contact the specific airline carrier for additional information and requirements.
Horses entering Canada must be accompanied by a valid US Health Certificate. The horse must be inspected by a licensed, USDA-accredited veterinarian within 30 days of export and must have a negative Equine Infectious Anemia (EIA or Coggins) test within six months.
Due to the confirmation of Vesicular Stomatitis (VS) in horses in New Mexico, horses that originate from New Mexico and US horses that have been in New Mexico within the previous 21 days may not be exported to Canada. Additional requirements are in place for horses from Texas and for Canadian horses returning from New Mexico.
Contagious Equine Metritis (CEM) certification for equines is also required for entry into Canada.
For current certification requirements and correct wording, consult USDA’s website, or contact the USDA Area office. After the US Health Certificate has been issued by the USDA-accredited veterinarian, it must be endorsed at the USDA Area Office in Tumwater.
Once the US Health Certificate has been endorsed, it is valid for 30 days following the date of issue. Horses can travel between the US and Canada as frequently as necessary during this period of validity, provided the EIA test remains current.
A brand inspection to verify ownership is required prior to movement of horses to an out-of-state destination. Check with the Washington State Department of Agriculture’s Livestock Brand Inspection Program, 1-360-902-1855 or firstname.lastname@example.org, for current requirements, procedures and fees.
For Canadian import purposes, “pet bird” is defined as a personally owned and cared for bird and applies only to species such as psittacines, song birds, toucans, canaries, finches, etc. “Pet bird” does not apply to pigeons, doves or poultry.
Personal pet birds must—
- Accompany the owner or
- Be in the possession of an immediate family member and
- Must be found to be healthy when inspected at the Canadian entry port.
The owner must sign a declaration at the Canadian entry port stating that—
- The bird has been in the owner’s possession for the 90 days preceding the date of importation and
- Was not in contact with any other birds during that time and
- The bird is the owner's personal pet and is not being imported for the purpose of resale.
The owner or any member of the family must not have imported birds into Canada under this pet bird provision during the preceding 90-day period.
For pet birds not meeting these requirements and for commercial shipments of birds and export of poultry, requirements can be found on the USDA website.
US-origin pet birds returning to the US through land border ports must also accompany the owner or family member and be inspected by a USDA port veterinarian at the US port of entry. The owner will be required to sign a declaration that the bird has been in his or her possession for the preceding 90 days and has not been in contact with other birds during this time.
Owners of pet birds entering the US by air or sea are required to obtain a US import permit and arrange for an inspection by a USDA Veterinary Medical Officer. For these birds and all other returning US-origin birds, requirements can be found on the USDA website.
Additionally, the US Fish and Wildlife Service (FWS) regulates importation of certain protected avian species. US-origin pet birds returning from Canada may be subject to additional US FWS requirements. Contact the US FWS at 1-800-358 2104 for further information and for all requirements.
To obtain the proper requirements for unusual pets, contact the USDA Area Office in Tumwater at 1-360-753-9430 or consult USDA’s website.
WSVMA meets with local DEA office about veterinary registrations
Members were recently made aware of concerns in California regarding potential changes in the DEA’s enforcement of the Controlled Substances Act (CSA). Veterinarians in the Sacramento area were contacted by the regional DEA office and asked to confirm that their DEA license was associated with a residence. During the course of that contact, the veterinarians were reminded that federal regulations prohibited them from carrying controlled drugs out of the location associated with their DEA registration. Of course, such a prohibition would prevent many veterinary practices from being able to serve their patients and clients.
The WSVMA recently met with the DEA to discuss the issue and how it affects local veterinarians. According to the Seattle DEA office, there has been no change in their interpretation or enforcement of the CSA. The DEA understands that the CSA does not really take into consideration the unique aspects of veterinary medicine that require more flexibility in the regulations.
The AVMA has been working with DEA officials in Washington, D.C. to address this issue. Federal legislation may be forthcoming, although it’s expected to take quite some time. If federal legislation is introduced, the WSVMA and AVMA will look to members for grassroots support for passage.
What can (or should) members do at this time? There is no need to change practices or procedures regarding DEA registration and recordkeeping or administration/dispensing of controlled substances. This is a reminder, however, to review those practices and procedures to ensure that they are in compliance. If you list your residence as the address associated with your DEA registration and you receive a request to confirm that information, complete the confirmation form and return it as directed. If you receive any communication from the DEA office that is of concern to you or you have questions regarding compliance with regulations, please notify the WSVMA.
Prescription Monitoring Program changes effective June 7, 2012
WSVMA sponsored legislation, Substitute Senate Bill 6105 (2012), successfully passed and was signed into law on March 29, 2012. The law exempts veterinarians from the current Prescription Monitoring Program and requires the Department of Health (DOH), in collaboration with the Veterinary Board of Governors (VBOG), to establish alternative data reporting requirements for veterinarians.
Veterinarians are required to report to the Prescription Monitoring Program only until Thursday, June 7, 2012. A parallel program will be developed over the coming year and the WSVMA will work with DOH and the VBOG to put new rules into place that will allow for the less frequent reporting of a greater supply of drugs. Changes will also include the ability to report manually and only those data elements relevant to veterinary medicine.
DOH encourages the continuation of reporting until the permanent rule is adopted some time in 2013, although it is not required.
For more information, please contact WSVMA at (800) 39-WSVMA or Chris Baumgartner, PMP Program Director, at (360) 236-4806 or email@example.com.
The WSVMA wishes to thank our members who helped with passage of this bill. Non-members who like these results, please consider joining the WSVMA and supporting the work we do to advance and protect the practice of veterinary medicine.
A message from the AVMA regarding DEA enforcement:
The AVMA was recently made aware of concerns in California regarding potential changes in the DEA’s enforcement of the Controlled Substances Act. Veterinarians in the Sacramento area were contacted by the regional DEA office and asked to confirm that their DEA license was associated with a residence. During the course of that contact, the veterinarians were reminded that federal regulations prohibited them from carrying controlled drugs out of the location associated with their DEA registration.
Of course, such a prohibition would prevent many veterinary practices from being able to serve their patients and clients. According to the national DEA office, there has not been a change in the DEA’s interpretation or enforcement of the CSA. The review of registration applications in California appears to be the result of a regional office confirming that the applicant’s principal place of business was indeed a residential address. It is a fact that the Controlled Substances Act (CSA) is written with this prohibition in place, but the AVMA has historically been informed that 1) the veterinary profession is generally not a target of enforcement in this area; 2) the DEA understands that the CSA does not really take into consideration the unique aspects of veterinary medicine that require more flexibility in the regulations; and 3) it will require a statutory change (i.e., federal legislation) to address the issue.
A subcommittee of the AVMA’s Council on Biologic and Therapeutic Agents (COBTA) has been tasked with evaluating this and other DEA-related issues. Our Scientific Activities and Governmental Relations Divisions have held a number of face-to-face meetings with DEA administrators to address the profession’s concerns. The California Veterinary Medical Association (CVMA) has requested a meeting with the area office and will keep us informed of the outcome. We are currently drafting a letter to the DEA Administrator to ensure the profession's concerns are formally on record. At the same time our DC staff will coordinate a letter to Congress, which we anticipate will also be signed by the state VMAs and allied organizations, addressing the need for a change to the CSA.
What can (or should) members do at this time? There is no need to change practices or procedures regarding DEA registration and recordkeeping or administration/dispensing of controlled substances. This is a reminder, however, to review those practices and procedures to ensure that they are in compliance. If you list your residence as the address associated with your DEA registration and you receive a request to confirm that information, complete the confirmation form and return it as directed. If you receive any communication from your area DEA office that is of concern to you or you have questions regarding compliance with regulations, please notify the WSVMA. If federal legislation is introduced, the AVMA will look to members for grassroots support for passage. If you’re not already a member, consider joining the AVMA Congressional Advocacy Network.
The AVMA will continue to post updates as more information becomes available.
Available resources on the AVMA website:
Veterinary compliance with the DEA and the Controlled Substances Act
Do you need a DEA registration?
Veterinary Practitioners’ Guide to DEA Recordkeeping Requirements
Veterinary Practitioners’ Guide to DEA Security Requirements
Official Identification and USDA’s proposed Traceability for Livestock Moving Intestate rule - WSDA, April 2012
USDA Announces Changes to European Union Animal Export Certification Procedures
The requirements for importation of dogs, cats and ferrets to the European Union have been changed. The revised veterinary certificates which must be used effective March 1, 2012 for all pet exports with destinations in the EU, are posted on the USDA APHIS IREG website.
To locate the revised requirements, access the web page and click on the beginning letter of the country of destination (Example: F for France). For a full description of the requirements for the new EU certificate, select European Union (blue or purple letters) under Summary of Requirements and then select “annotated certificates with explanatory notes."
Although bilingual certificates are now required, they are not yet available for all EU countries. Bilingual certificates will be posted on the USDA APHIS IREG website as they become available. In the interim, English certificates can be used for those countries without bilingual certificates.
The new certificates are valid for animal entry for ten days from the date of the accredited veterinarian signature. Dogs (not cats) going to Finland, UK, Ireland and Malta require an echinococcus treatment greater than 24 hours, but not more than 120 hours (five days), prior to country entry. The UK has confirmed that it will accept echinococcus treatment after the accredited veterinarian prepares and USDA endorses the health certificate.
It should be noted that Finland, Ireland, and Malta have not accepted post endorsement echinococcus treatment at this time. The accredited veterinarian should be aware that this fact effectively reduces the certificate validity to five days from the date of accredited veterinarian signature date for dogs traveling to those specific EU countries. For these countries, USDA cannot endorse the export certificate until the treatment has been given and verified by the signature of the accredited veterinarian.
USDA has also been advised that the UK is requiring confirmation that dogs, cats or ferrets were vaccinated for rabies after the implantation of the microchip. In order to confirm this, the accredited veterinarian must prepare a statement on letterhead verifying that the chip ID was read prior to vaccination. Please submit the signed statement with the export packet.
Following review of the information available on the USDA APHIS IREG website, if further information is needed, please contact the USDA, APHIS, Veterinary Services’ export office. Contact information can be found on the local veterinary services website.
New rabies rule in effect
Beginning January 1, 2012, all dogs, cats, and ferrets in Washington must have up-to-date rabies vaccines. Any mammal can get rabies. However, bats are the only animal in Washington known to carry rabies. In other states, raccoons, skunks, foxes, and coyotes are known to carry rabies. Many cities and counties required rabies vaccination for pet licenses before the new state rule took effect. The rule, WAC 246-100-197, says an owner of a dog, cat, or ferret shall have it vaccinated against rabies and revaccinated following veterinary and vaccine manufacturer instructions. An "owner" is any person legally responsible for the care and actions of a pet animal.
The Washington State Departments of Health and Agriculture have no provision for rabies vaccine exemption through the use of rabies titers. It is recognized that rabies vaccination may under specific conditions pose an unacceptably high risk to the health of an individual animal. This is a decision made by the owner in conjunction with their family veterinarian and should be documented in the medical record. However, if the pet that does not have proof of current rabies vaccination is exposed to a potentially rabid animal or bites a person, the pet would be looked upon by public health as a non-vaccinate. Washington State follows the Compendium of Animal Rabies Prevention and Control developed by the National Association of State and Public Health Veterinarians which does not accept titers as an alternative to vaccination for reasons stated in the document.
Rabies is still not common in Washington State. The Department of Health tests 180 to 350 animals each year. In 2011, they tested 193 bats and found 11 that were infected with rabies. It is very rare for a person to get rabies in Washington. However, 251 people had to receive the series of shots (known as post-exposure prophylaxis or PEP) in 2011 following their exposure to potentially rabid animals. In December 2011, a person in Thurston County was bitten by a rabid bat that was sleeping in a bedroom slipper.
The last reported case of rabies in an animal other than a bat in Washington State was in 2002. A cat developed rabies after catching a rabid bat. The last reported human cases of rabies in Washington were in 1995 and 1997. In 2007, a puppy imported from another country passed through Washington on its way to another state. It was diagnosed with rabies shortly after arriving at its destination. While the puppy was temporarily housed in Washington, several people were exposed to the puppy and had to undergo post-exposure prophylaxis.
There is no fine or enforcement at the state level. However, the intent of this new rule is to educate pet owners about the rabies vaccine so they’ll protect their pets, themselves, and their families. Any fines would come from cities or counties. Many communities already require proof of rabies vaccination in order to get a pet license.
If a pet is not vaccinated, and is bitten by a stray or wild animal, the pet needs to be confined and observed for up to six months. If the pet shows signs of rabies while in confinement, the animal must be euthanized in order to be tested for rabies. For more information go to www.doh.wa.gov.
Rules for the safe handling of hazardous drugs adopted
The Washington State Department of Labor & Industry’s rule on occupational exposure to hazardous drugs was officially adopted on January 3, 2012. It is expected to be published in the Washington State Register in two parts (on January 18 and February 1, 2012). This new rule can be found on the Labor and Industry website, including on this webpage is the explanatory statement and frequently asked questions.
The dates of implementation are January 1, 2014 for the development of a hazardous drug program and enactment of these regulations except the training of staff and the installation of appropriate ventilated cabinets. These latter two are to be implemented on July 1, 2014 (training of staff) and January 1, 2015 (installation of appropriate ventilated cabinets).
If you are interested in attending a stakeholder’s meeting about the formation of the Hazardous Drugs Advisory Committee and development of the model programs, it will be held January 25, 2012 in Tumwater. This meeting will be to develop model safety programs for the different types of medical and research facilities that are using these drugs. These model programs would also potentially be used by those who would be responsible for those who would be performing inspections and enforcing the regulations.
For more information on these rules and how to implement them in your practice please contact Dr Lisa Parshley (firstname.lastname@example.org).