After Hurricane Irma struck in 2017, we responded to the British Virgin Islands where the storm had caused terrible devastation. Many people were forced to evacuate the island, but it was difficult to find transport for their animals. So, after providing the dogs required veterinary care, we flew these dogs, as well as unowned dogs, to the U.S. where they could be reunited with their owners or placed for adoption in cases where reunification wasn’t possible.
It was an honor to be able to help dogs and their families in the face of such devastation, and it was a powerful example of the great good that we are able to do in emergency situations worldwide. Our international rescue work saves dogs from desperate situations around the world, such as shuttering dog meat farms in South Korea and flying rescued dogs to the U.S. to find them homes, or sparing animals from the butcher’s knife in a dog meat market and putting them on the path to adoption.
But a new policy being considered by the Centers for Disease Control and Prevention could severely impact such efforts, while also complicating the lives of individuals with pets and rescues. While well-intentioned in aiming to prevent the spread of zoonotic disease, the proposed rule is misguided in its requirements and in the logistics of its implementation.
The CDC is proposing to amend its regulations on dog imports, impacting rescue operations, as well as people traveling internationally with their dogs.
Currently, the CDC regulates dog imports under a temporary rule, which applies to dogs who are imported into the U.S. from countries deemed to be high risk for canine rabies. Now, the proposed new rule greatly expands these regulations by creating requirements for dogs imported into the U.S. from all foreign countries—not just high-risk rabies countries. It also requires importers to submit a CDC import form prior to travel, and the rule does not clarify if CDC staff need to review and approve forms for dogs coming from non-high risk rabies countries, or if an automatic clearance is granted.
Submitting an import form prior to travel, on its face, seems like an easy requirement. However, our experience with the CDC’s current system reveals a two-month turn-around time for imports of dogs from countries categorized as high risk for canine rabies. Other agencies with comparable e-filing systems yield similar slow response times for form processing, creating a paperwork clog that is unrealistic for people traveling with pets and rescue groups organizing time-sensitive missions. We are concerned about the agency’s ability to process this required paperwork in a timely fashion, especially since it proposes to dramatically increase its regulatory volume by requiring all imported dogs to have an import form prior to travel, and not just dogs imported from high-risk rabies countries.
A key concern is that the proposed rule requires importers show documentation that their dog has not been in a high-risk rabies country for six months before arriving in the U.S., regardless of the country the dog is being imported from. The proposal fails to provide guidance on how a person should prove that.
Any dogs denied admission into the U.S. must be returned to the country where they came from within 72 hours. Requiring proof of a dog’s whereabouts for six months is especially problematic for rescue dogs or dogs adopted by Americans overseas.
For example, in the case of our Hurricane Irma disaster response, we had no way to gather “proof” that these animals had been on the island, a rabies-free country, for six months. Yet without allowing these dogs into the U.S., these animals and their families would not have been reunited and unowned animals would have been left to their own devices, as the only animal shelter on the island was destroyed. By including this poorly worded provision in the proposed regulation, rescue organizations offering lifesaving aid and people traveling with their dogs, including therapy dogs, personal pets, and government officials and military families returning from deployment, could have their dogs sent back to the country of export, all at the expense of the importer.
We are committed to using rigorous health and vaccination practices so that we can transport dogs to our shelter and rescue partners that secure adoptive homes for them in the U.S. We do not have to choose between maintaining public safety and saving animals’ lives if there are reliable and realistic health and vaccination practices in place. We can proactively prevent zoonotic disease spread in the U.S. and aid in the global eradication of rabies while also allowing animal welfare organizations to responsibly save dogs across the world and letting people travel safely with their trusted companions.
Sara Amundson is president of the Humane Society Legislative Fund.