Call to Action! Back to Unregulated Puppy Mills?

posted April 4th, 2012 by
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Oklahoma City - State Capitol

Please contact your legislators today.

Oklahoma Senator Josh Brecheen, known for his goal of repealing the much needed regulations of puppy mills in our state is at it again.  Yes, Brecheen wants Oklahoma puppy mills to be allowed to keep dogs in the dark, in filth, in tiny cages and without clean water. He believes they may be bred for two litters before being considered breeding females. Most importantly he submitted a bill which would place into statute that Oklahoma regulations could be lower than USDA standards.


Vote NO on HB2921 !


REPEALS the Commercial Pet Breeder Act of 2010


ABOLISHES the Commercial Pet Breeder Agency and the administrative rules by placing oversight and regulation of pet breeding under the Department of Agriculture–an industry outside their scope–without benefit of the knowledge, experience and technical competencies of the existing board of directors (or advisory council)


HALTS regulation of dog breeders for at least the next 18-24 months


STOPS the implementation of existing regulations and will delay it for another two years because of the undefined and restrictive regulation language.  The existing board began regulation October 3, 2011, due to transition time and the numerous steps required to begin implementation. HB2921 will require the Department of Agriculture to face these same issues and timing delays.  Unlike SB1919 that transfers the board and existing rules, HB2921 ignores the expertise gained over the past, two years and starts a two-year process back to square one.


The latest amendment by Sen. Brecheen does not even allow the Dept. of Ag to write new rules, requiring it to instead, to follow minimum USDA regulations. These are regulations that both the Assistant Attorney General and General Counsel for Dept. of Ag. have said will render regulation nonexistent due to the imperfect fit.  The language is not even applicable to regulation of the pet breeding industry.


This highlights one of the difficulties in placing an industry which breeds and raises companion animals under the same USDA guidelines as livestock animals, used as a food source. There is no consideration of the need for socialization prior to the animal being placed in a family home or the physical and medical requirements of the various breeds of dogs and cats.


Another problem with HB2921 is that it actually raises the minimum number of dogs a breeder may have before the facility is regulated HB2921 changes the definition of an adult female from 6 months to 18 months which will very likely raise the minimum to 20-30 dogs before registration is required. A breeding female mother can produce three litters of puppies before she is 18 months and is counted as an “adult female” for regulation purposes. With this change, an Oklahoma breeder could have 20-30 intact breeding females, and avoid being regulated. In contrast, 20-30 breeding dogs is the maximum number of dogs allowed in breeding operations in many other states.


Over the past two years, this board gained significant institutional knowledge and technical competencies while creating a regulatory framework for the agency.


The board is also the watchdog for the regulations implemented on Oct. 3, 2011, just six months ago. Oklahoma now has over 230 licensed breeders. Most of these breeders detest our state’s reputation as a haven for puppy mills and substandard dog breeding operations. They are sickened by the conditions of puppy mills like those in Dibble which received national attention through the internet and news services. (Just ask McClain County Sheriff Don Hewett what he thinks of puppy mill breeders!)


HB2921 repeals current regulation while placing unreasonable restrictions on future regulations. It is ineffective for eliminating puppy mills.



Vote Yes on SB1919 !


- Transfers the Commercial Pet Breeder Board, in its entirety, to the Department of Ag


 – Maintains momentum.


- Fortifies enforcement using the Department’s own investigators.



SB1919 is simple, and it is the right thing to do!

Sent to us by our good friends at the Oklahoma Alliance for Animals

One Response to “Call to Action! Back to Unregulated Puppy Mills?”

  1. Debi says:

    First off, I would like to ask who the author of the article is. The article says ‘Posted by Steve” but does not clarify who wrote the article. In commenting on the article, identification is required, so should it not be the same for the author of the article?

    Let’s address the article bit by bit. Senator Brecheen is not allowing “to keep dogs in the dark, in filth, in tiny cages and without clean water. He believes they may be bred for two litters before being considered breeding females.” HB2921 was authored in the House by three, count them three, veterinarians: Richardson, Renegar and Denney. Sen. Brecheen is from an animal production background.

    HB2921 would mandate that the standards of care would be no more stringent than USDA requirements. Nowhere included in the bill does it say that they would be less. Regarding your statement of breeding age: It is the current regulation of SB1712, and the proposed bill SB1919 that define an adult animal as 6 months of age or older and would allow for them to be bred. HB2921 defines an adult animal as 12 months of age or older and does not allow for any younger to be bred.

    HB2921 places the oversight of pet breeders under the Oklahoma Department of Agriculture. Yes, it is true that it would abolish the Oklahoma Board of Commercial Pet Breeders and the current rules. The OBCPB has proven time and time again to be an out of control board with no regard for legislative intent or the law. Consider their actions of citing without inspecting, illegal searches of breeders who do not fall under the regulations and self proclamation of “we will continue to do so,” as published in the Tulsa World in October of 2011. Let’s consider that it is Sue Ann Hamm who wrote SB1712, funded the state agency created there from, sits on the board of this agency, and sits on the board of the Central Oklahoma Humane Society. This is a clear and definite conflict of interest and appearance of impropriety (bought and paid for legislation). Moving oversight and returning pro rata the funds to Mrs. Hamm removes further appearance of impropriety and removes the conflict of interest.

    The Oklahoma Department of Agriculture has a long history of oversight in animal agriculture, so this would not be “outside their scope” as you claim. As for the “knowledge, experience and technical competencies of the existing board of directors (or advisory council)”, well, I believe this board has proven to be a detriment to themselves. Consider the statement of Rep. Gus Blackwell to the board regarding their behavior and competency at the proposed rule changes comment hearing earlier this year: “You have failed completely.”

    You state that HB2921 “HALTS regulation of dog breeders for at least the next 18-24 months.” This is not a true statement. HB2921 allows for emergency rules to be implemented from the start, with rules to be promulgated by the Dept. of Agriculture. Current rules would remain in effect until July 1, 2012. There would be no lapse in time of regulation. You are forgetting that Oklahoma has had Title 4 and Title 21 for a number of years. Then there is always the Animal Welfare Act on the federal level. I am quite sure that the Dept. of Agriculture has the knowledge and expertise to implement the proposed emergency rules. Nothing is back to “square on” as you claim.

    You state that HB2921 “does not even allow the Dept. of Ag to write new rules, requiring it to instead, to follow minimum USDA regulations.” Apparently you have not read the proposed bill fully, or are choosing to twist the verbiage contained in the bill. Let me quote a portion of the bill for you: Under Section 3, Paragraph B: “The Board shall adopt the rules necessary to enforce and administer the Commercial Pet Breeders Act of 2012, including but not limited to rules that:
    1. Establish standards for care that are no more stringent than United States Department of Agriculture specifications for the humane handling, care, and treatment of dogs and cats; 2. Establish reasonable and necessary fees; 3. Establish provisions related to initial and renewal applications, revocation or nonrenewal of licenses, procedures for sale of animals, and procedures for making complaints; and
    4. Establish any other rules deemed necessary by the Board.” I hope that this clarifies it clearly enough for you.

    In your statements of the difficulties of moving oversight “under the same guideline as the USDA,” I am in disagreement with these. The USDA has been overseeing pet breeders for a great number of years. Think about how long, and the great number of USDA licensed breeders, have been under their oversight. USDA guidelines include socialization of the animals, so again, this is a misstatement on your part.

    In regards to your statements in the next paragraph, we have already addressed the breeding age issue above. For your next two paragraphs, I do not agree with the statements included. The OBCPB has acted heavy handed and illegally on multiple occasions. Please explain why they cannot seem to keep an Executive Director employed? Please explain the complete and utter disregard for the intent of the Legislature and the law? Please explain the complete and utter contempt for any and all breeders, good or bad, large or small, ad regardless of the standards of care given by said breeders? Please explain why Angel Soriano, the Chair of said board, to my knowledge, has never been USDA licensed nor has raised a litter in over three years, yet is supposed to be the “Commercial pet breeder representative” of this board? Odd that he has chosen not to raise any litters since regulation has been in effect. Could it be that he could not meet the standards he and the board have imposed on the breeders themselves?

    You are correct in your statement that “most of these breeders detest….” Responsible breeders do not want sub-standard kennels in our state , as this hurts the industry they love.

    HB2921 is a much more common sense bill than the current situation or SB1919. Again, think of the differences in the definition of an adult animal. The Dept. of Agriculture does not need the current board as an Advisory Council, nor do I believe they want them in that capacity. They have much more than 2 years “experience” as an animal agriculture oversight agency. The appearance of impropriety and conflict of interest would be gone, and so would the harshness and heavy handedness of this board. Let’s remember that prior to this board, there were approximately 1100 USDA licensed breeders in the state. Currently, with the actions of this board, that number has dropped to around 300. This board has cost the state much in needed revenue and loss of income for a number of veterinarians and suppliers.

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