International Pet & Animal Transportation Association
IPATA
"The International Pet and Animal Transportation Association is a non-profit trade association of independent members who are dedicated to the safe and humane transport of pets and other animals"
ID: 514692818178-82
Lobbying Activity
23 Sept 2019
THE ANIMAL TRANSPORT ASSOCIATION (ATA)
In response to the European Commission consultation on SANTE/7164/2019 (POOL/G3/2019/7164/EN.docx) ... (2019) XXX Draft, establishing detailed rules on the operations to be carried out during and after documentary checks, identity checks and physical checks on animals and goods subject to official controls at border control posts
We have serious concerns regarding the 'detailed rules for physical checks' for live animals as described in Article 4. Although we understand that in some cases, physical random checks are absolute required, we have our concerns about the wellbeing and safety of live animals that are being physically checked, especially in case that they would have to be offloaded / reloaded. As you are probably aware, most accidents with shipments of live animals do happen at loading or unloading. We also have our doubts if the border control posts are well equipped and suitable for accommodating various species of live animals in optimum conditions and securing the wellbeing and safety of all animals having to be offloaded and reloaded.
Particularly in the case of vulnerable, pregnant or young animals, the requirement for unloading and reloading to undertake individual identity and clinical checks, simply places unnecessary stress on these animals, as well as potentially introducing them to additional disease risks. It also unnecessarily prolongs their journey. None of these factors is in the welfare interests of any live animal. In addition, these requirements will place an additional unnecessary workload on BIP officers. Not to mention the legal responsibility for the operator of the BIP, it's staff and the animal attendants (if any) in case of incidents.
We believe that it is in the health and welfare interest of live animals for this legislation to allow checks - where possible - to be done on the vehicles and offloading should be avoided and/or minimized, unless there would be a serious concern by the inspecting authorities (f.e. on the compliance of the animals with documentation/legislation, the safety or wellbeing of the animals or in case of a possible danger for public safety).
Thanking you for your consideration, we remain,
Yours sincerely,
Filip Vande Cappelle,
President ATA.
Read full response12 Jul 2019
Feedback is based on all terrestrial animals and the necessary variations mentioned in specific relation to Dogs, Cats and Ferrets with emphasis on those notes which do not allow or have not discussed for a variation under dog, cat and ferret.
Pg 12 – Point 54 – What is the definition of confined establishment. Is this particularly referring to quarantine restriction imposed by a member state to which the animals are destined.
Pg 29 – All health inspections now 48 hours before time of loading onto aircraft for departure to the EU, this is changing from 10 days?
Pg 29 – Article 14 Point 1 – Will there be approved routes for terrestrial animals to the Union given, i.e. we cannot transit a country on an airline not in the Union as there are no guarantees that animals travelling on the aircraft or at the transit facility are all destined for the EU. i.e. Johannesburg to Basel we cannot send with Emirates? Can we have confirmation that this point refers to first point of entry in the Union and not final destination. I.e. Johannesburg to Basel with Lufthansa transiting Frankfurt. It also cannot be confirmed that transhipment in Frankfurt will be free of animals transiting Frankfurt from origin outside of the Union and final destination is outside the Union. As such there may be animals in transit that have not been subject to the same testing requirements for entry to the Union.
Pg 29 – Article 14 Point 3 – does this mean that animals may not be taken off the aircraft to a handling station, how is transfer of aircraft to be handled. This implies that airlines will need to verify the total final destination and health requirements of all animals on board and know what they can and cant mix. (This ties into my query at point 1 re transhipment of third countries as well as countries within the union)
Page 31 – Article 17 point b – is this required for newly constructed containers. Is there a list of preferred disinfectants that will be recognised and / or their active ingredients to minimise variation and non-compliance
Page 63 – Article 74 – there is a variation to the General movement for terrestrial animals. (see above point for page 29) is this indicated that dogs and cats may enter the Union by transhipment. Can it be clarified that the additional requirements imposed under Article 14 are not relevant for dogs, cats and ferrets and they may travel with other of their species not destined for the Union with a possibly differing health status and there is no requirement on the airline to declare status of all animals onboard for entry to destination.
Page 63 – Article 74 – implanted transponder noted. Is the ability for a tattoo being removed, whilst discussed in PART-2019-176971V2 the tattoo mention, this is not referred to in first document.
There is also no specification to date of implant being before rabies vaccination before titration drawn 30 days after, can this be confirmed as continued and valid.
Page 64 – Article 76 – in reference to third countries listed under Regulation No 577/2013. Will the United Kingdom and Northern Ireland be added to this list and the regulation updated as there is currently no mention of where the UK will be classed.
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