On March 5, 2018, the Department met with an advisory group of licensed dog sellers. The committee members represented entities selling more than 50 days per year, entities selling fewer than 50 dogs per year, dog shelters, dog dealers, and dog breeders. The Department’s Animal Health Division asked the committee of stakeholders to provide feedback as to whether the proposed rule provisions would be onerous or burdensome in any way. The Department also wished to learn about what potential financial costs might result from the proposed rule changes.
Results from this meeting with stakeholders were both positive and encouraging. All participants agreed that the proposed changes added useful clarifications to the existing rule. The stakeholders indicated that the proposed rule changes would not be burdensome. No stakeholder foresaw any significant costs associated with the implementation of the proposed rule.
As a final note, the advisory committee members also strongly encouraged the Department to incorporate statutory requirements into the rule as most dog sellers refer to the rule only when seeking program requirements.
Reporting, Bookkeeping and other Procedures
The current rule requires that health records be kept. These records include vaccinations, observation and treatment records and whether the health care was administered by the license holder or by a veterinarian. The proposed rule clarifies that vaccination records must include the name of the vaccine manufacturer, vaccine serial number and lot number, and the date on which the vaccine was administered. This vaccination information is required because:
- Pursuant to Wis. Stat. § 173.41 (8) (a) 2., a copy of all vaccination records for the dog is required to be provided to the purchaser. This information includes the date it was administered and the name of the person who administered it. - The specific vaccination information in the proposed rule (vaccine manufacturer, serial number and lot number, and date of administration) is currently required to be provided on the CVI of any dog sold. The CVI only reflects the vaccinations provided by the veterinarian who issues the CVI. For consistency and completeness, the same vaccination information required on the CVI should be kept in the dog’s record, including any vaccinations administered by the dog seller.
The fiscal costs relating to these bookkeeping requirements are expected to be minimal and are required for the welfare of the purchaser.
Professional Skills Required
The proposed rule does not specify any professional skills required for small businesses.
Accommodation for Small Business
Many of the businesses affected by this rule are small businesses. The requirements in the proposed rule are necessary for the health, comfort, and welfare of the dogs and puppies being kept and for the protection of consumers purchasing those dogs and puppies. For that reason, this proposed rule does not make special exceptions for small businesses because the rule’s requirements apply equally to all businesses, large or small.
Conclusion
This rule will generally benefit affected businesses, including small businesses. This rule will not have a significant adverse effect on small business nor will it be subject to the delayed “small business” effective date provided in Wis. Stat. § 227.22 (2) (e).
