Dr. Chester Gipson
APHIS/USDA
chester.a.gipson@aphis.usda.gov
(301) 734-4980


Dear Dr. Gipson:
 
In mid-2005 APHIS/USDA put out a request for public input regarding the
amendment of the Animal Welfare Act to include ferret-specific regulations to
govern the handling, care, treatment, and transportation of domestic ferrets.
The thousands of answers that you received from ferret owners, veterinarians,
ferret shelters, and breeders across the United States in response to your
request clearly indicated a resounding "YES", that ferret-specific regulations
are greatly needed and long overdue.

In spite of the overwhelming response in support of ferret-specific regulations
it has come to my attention that the USDA is proposing to lump domestic ferrets
with existing regulations governing all warm blooded mammals.  It is with this
letter that I express my deepest concern regarding this proposition.

The only way to ensure that ferrets are not being shipped prior to 8 weeks of
age is by enforcing dentition requirements as proposed by the American Ferret
Association in their response dated September 23, 2005.  Not only does including
ferret kits in with regulations governing all warm blooded mammals not allow for
this verification of age; it also does not provide urgently needed safeguards as
the AFA has proposed with the adoption of ferret-specific regulations. 

As stated in the thousands of responses you've received, such regulations for
domestic ferrets must be separate from those governing other mammals in these
areas, as ferrets have unique biological, physiological, and social needs.  To
ignore the call for ferret-specific regulations with a decision to simply lump
domestic ferrets with all warm blooded mammals is an injustice to the ferret
community as 'consumers' of the ferret trade and a continuing endangerment to
the domestic ferret.