Points to Make in Writing the USDA and Sample Letters

On the need for regulations

Suggested regulations

Please note: The USDA does not regulate pet stores, which fall under state or local jurisdictions. Comments on conditions in the pet stores is not relevant.

Other suggestions

Testimony needed with detail of numbers, costs, etc.

A true story about ferrets at airports.

Dear APHIS Animal Care Experts,
I am so very grateful that the USDA is now seeking input on some of the ways that current regulations fail to protect ferrets, Docket 04-088-1.
There is barely a month on any major ferret electronic list when someone does not seek help with a kit who was transported and sold too young. This was not always the case. Before ferrets became so popular the typical pet store ferrets were at least 8 weeks of age, a safe age for transportation and sale of healthy kits. This is not just personal recollection. I have heard it from others, including those at one of the major farms who told me that competition forced them to lower their shipping ages from 8 weeks to 6 weeks.
Eight weeks also is an easy age to check because when a kit is 8 weeks of age the conical adult canine teeth are replacing the needlelike kit canines then, so all one has to do is to look for adult shape canine teeth. (At 50 and 53 days approximately they also erupt first molars, both mandibular and maxillary, meaning that they can deal dentally with the sort of diet a pet store will provide.)
Just as it is financially feasible for the ferret farms to sell kits at no younger than 8 weeks of age, it is also not an economic burden upon pet stores. Petsmart has been selling ferrets at no younger than 12 weeks of age since last year.
I wind up reading of too many situations in which kits were so undeveloped and unready for weaning that they could not properly eat kibble, or they wound up with painful rectal prolapses.
We ourselves have cared for such kits. One, aged by later dental eruption, fit in the palm of my hand, and I have tiny hands for a woman. By dental age obtained later she was barely 5 weeks old when she joined our family. Our vet had to help us with a milk replacer that we gave as well as food slurry. She would keep entering my clothing not only for comfort but to try to suckle from me -- a very unusual behavior but one which emphasizes that she was among those who were sold too young. Thankfully, she was not among those who develop serious health problems from being sold so young, but she did require special care.
Another well known problem is that of poor temperature control during transport. Ferret kits are highly vulnerable not only to rapidly induced hunger and dehydration, but to temperature extremes, especially high temperatures. In fact, ferrets of any age have difficulty with high temperatures. Several times already there have been news stories, or internet rescue conversations about unacclimated ferrets who were exposed to temperatures of over 80'F for too long who died or suffered brain damage at airports or elsewhere in transit, sometimes also acquiring kidney damage when dehydration also occurred. This would be so easily avoided if people simply understood the conditions ferrets need to survive.
With the large increase in ferret popularity far too many people have tried to cash in without knowing what they were doing. This has led to a number of products which are inappropriate to ferrets (and out of your control) as well as many people breeding without any idea what they are doing in terms of health and longevity. Some of those include some farms, and farms are the sellers who are controlled by USDA regulations. One of the bad farms sold several years ago. Reports from people I trust were that their cages had flooring that was wire with openings too large for safety, but that is not all. They chose that size of wiring because they were having pigs walk below the cages and eat dropped feces and food as a way to reduce their labor. I don't have to tell you what sort of zoonotic problems can arise when three species prone to influenza (humans, ferrets, and pigs) live in that sort of close contact. Just as with those in charge of transport knowing too little about ferret health needs, so, too, do some farms know too little, or care too little.
I would like to see a group of new ferret-specific regulations which take into account the ways that ferrets differ from dogs and cats, and I strongly think that the best regulations would be designed by ferret veterinarians.
Thank you so very much again for all of your hard work! The problems which exist are not at all caused by only one farm, one transporter, or one distributor. They are encountered across the board. In some cases, as with the mid sized farms which first began selling at young ages the choice was their own and ferret health was ignored. In other cases other farms, including a large one, felt pressured to reduce their ages of sale due to the competitive pressure created by the first group. Many other times the harm to ferrets comes just from ignorance on the parts of farms, distributors, or transporters. These are only three of the risks that exist currently or recently existed. Ferret-specific regulations would go a huge way toward correcting such difficulties.With gratitude,
Sukie Davis Crandall
Ferret Health List co-moderator
International Ferret Congress advisor

I am writing in support of the petition to create ferret specific regulations to govern the handling, care, treatment and transportation of domestic ferrets. Such regulations are greatly needed and long overdue.
Ferrets have become increasingly popular pets over the last couple of decades. As a result, there is increasing demand at pet stores to sell ferret kits, and thus increasing pressures on ferret farms to ship more kits early and quickly. Unfortunately, this is to the detriment of the animals. They are often taken from their mother and littermates at too young an age, spayed and neutered, and then shipped before surgical incisions are healed or they have the dentition to handle the kibbled food they are now forced to eat.
The key provision that should be part of these regulations is a minimum age of transport. A key way to determine this age is by dentition—by 8 weeks of age, the easily identified canines have erupted along with the molars necessary to eat kibble.
Other provisions should protect ferrets from extremes in temperatures, provide for frequent access to food and fresh water, allow for adequate space for exercise, and provide social interaction. As intelligent, curious animals, being stuck in a small cage all day with no opportunities to exercise, play and interact is like jail to them.
Social interaction is especially important so that the animals will be well adjusted and make good pets. Too often ferrets end up in shelters because they have not learned how to interact with humans.
Linda Iroff
Co-Director, International Ferret Congress
Director, Ohio Ferret Coalition
former ferret shelter director

I am greatly relieved to see the USDA considering possible amendments to the Animal Welfare Act to provide protection for ferrets.
Currently, domestic ferrets are thought by many to be the 3rd most popular domestic house pet, behind the cat and the dog. Sadly, the protection afforded to them by the Animal Welfare Act does not take into account the specific biological, physiological, and social needs of this animal in a manner consistent with other household pets. As a result, ferrets are commonly being shipped to pet stores - already spayed/neutered, descented, and vaccinated - at an age younger than they would even naturally be weaned.
I examined nearly 100 ferrets upon arrival over a several month period at several pet stores near Bangor, Maine. In the course of my physical exam, I found approximately 30% of the ferrets to be ill enough to be classified as "unfit for sale". I witnessed animals that were estimated to be as young as 5 weeks of age at the time of arrival for sale. The conditions that I noted included prolapsed rectums, unhealed and infected surgical incisions, congenital malformations, pneumonia, upper respiratory infections, severe diarrhea, and starvation/emaciation. In addition, the toll of behavior changes associated with inappropriately early weaning and shipping prior to the emergence of adult dentition include nipping, biting, and hyperactivity. This combination of health problems and behavior problems results in the relinquishment of animals to already overburdened shelters. Many of these problems could be corrected with an older age at weaning and shipping, and standardized requirements for basic care.
One of my personal ferrets, now famous for his "testimony" before the State of Maine during the hearings for the "8-week Rule" adopted there, nearly died during shipment/re-sale. I was shopping at the local pet store for supplies, and a conscientious store clerk pulled me aside to let me know that a very sick ferret, slated to be "snake food" that evening, would be in the back seat of my car when I left - would I please take care of him and euthanize him if he was suffering. I went outside to find an unconscious, barely breathing tiny white ferret in my car. He was approximately 5 weeks old and only had baby teeth. I rushed him to my hospital, where my staff slowly warmed his body temperature and began to nourish him. Within 12 hours, he had regained consciousness - and within 2 weeks, was a normal kit again. Fortunately, someone cared enough about him to bring him through. How many ferrets need to suffer and die before standards are set for their protection?
The Animal Welfare Act MUST be amended to protect not only the ferrets, but also the consumers. People buy these ferrets, assuming that they are getting a healthy, fully weaned animal. Instead, they are taking home kits that have baby teeth, need softened food, and are so biologically stressed from their early weaning and surgeries that they have often fallen prey to multiple illnesses. Pet stores, unfortunately, also suffer because they need to deal with these unhappy customers and these sick animals. Shelters wind up taking in the animals needing medical and behavioral care when the consumers are no longer willing or able to work with the ferrets. And, of course, the ferrets are the ultimate losers in this equation.
What would I like to see done to protect these popular pets?
-Allow no animal to be shipped from the breeder prior to 8 weeks of age, as evidenced by the emergence of adult dentition.
-Set humane shipping standards, maintaining animals within a natural thermoneutral zone (air temperature, not cooled with gel packs as is currently the norm). Ensure that they are provided adequate non-spillable food, water, and bedding to last the duration of their trip plus allow for travel delays.
-Require that a health certificate be issued for each and every animal to be shipped, not a litter certificate.
-Require that surgical incisions be healed and that the animal be free of all apparent disease prior to transport.
-Provide for minimal care standards for all animals maintained on a ferretry.
These requests are minimal, basic requests which fall under the existing scope of the Animal Welfare Act. Not providing species-specific requirements covering ferrets is contrary to both the language and Congressional intent of the Animal Welfare Act.
I would be happy to discuss this matter further. It is a petition that is too long in the coming. Every day that we delay, more animals die of neglect and ignorance. Protecting the ferrets provides a win-win situation - for the consumer, the pet stores, and of course, the ferrets.
Sandra C. Kudrak, DVM, DABVP