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The AKC and AKC Companion Animal Recovery (AKC CAR) filed comments on September 6, 2006 with the United States Department of Agriculture's Animal and Plant Health Inspection Service (APHIS) on the establishment of federal regulations for the microchip identification of animals covered by the federal Animal Welfare Act (AWA). The comment letter was filed in response to an Advance Notice of Proposed Rulemaking by the APHIS requesting public input. The complete text of the AKC's comments, as well as those of other organizations and members of the public, can be accessed at http://www.regulations.gov. The AKC also participated in five of six public hearings on the same subject hosted by the APHIS across the country during the summer.

Under the AWA, the APHIS has authority to regulate research facilities, exhibitors, auction houses, transporters and persons who sell pets at wholesale. The regulations include requirements for the positive identification of all animals. The AWA does not cover private pet owners and persons who breed and sell dogs only at retail, so any regulations pertaining to microchip identification will not apply to such persons.

Currently APHIS regulations require positive identification of covered animals by an approved collar, tag, or tattoo, and, in some cases, a card affixed to the animal's primary enclosure. APHIS regulations do not now include the option of microchip identification. In 2005, Congress directed the APHIS to examine the issue of microchip identification of pet animals, with a particular emphasis on harmonizing microchip systems used in the U.S. and internationally.

In its comments, the AKC urged the APHIS not to harmonize the two microchip technologies by mandating the exclusive use of one system or the other, but to specify standards for the performance of a microchip reader (scanner) that will effectively and efficiently read all chips in common use in the U.S. and internationally, and then permit the use only of chips that can be read by such a scanner. This recommendation, if adopted by the APHIS, would assure that virtually all of the estimated 5 to 10 million microchips already implanted in pet animals in the United States could continue to be read, while also accommodating the growing number of dogs imported from abroad or which travel abroad. It would also provide the public with the widest choice of microchips.

The AKC also noted that most persons who microchip pet animals do so for the purpose of identification and recovery if the animal is lost or stolen. Experience with the 2005 hurricane season, in which large numbers of pets and pet owners were dislocated, demonstrated the value of microchip identification and also the problems that result when people do not microchip their animals, fail to register the microchip with a recovery service, or fail to keep their contact information up-to-date. The AKC urged the APHIS to include in its regulations provisions setting standards for the creation and maintenance of microchip data bases, including access to the information for recovery purposes.

The AKC created AKC CAR in 1995 as a comprehensive, not-for-profit recovery service to reunite lost pets and their owners. The AKC CAR is currently the largest not-for-profit database and recovery service in the United States, with nearly 3 million animals and owners registered. The AKC CAR has made nearly 300,000 pet recoveries since its inception. While the AKC CAR registers animals identified by an approved collar tag, an approved tattoo or a microchip, the vast majority of animals registered with the AKC CAR are identified with a microchip. The AKC CAR registers animals identified with all microchips, and does not sell microchips or scanners. In addition to maintaining a 24-hour, 365 day recovery center, the AKC CAR educates the public about the value of microchipping their pets and has donated thousands of scanners to pet recovery organizations. During the 2005 hurricane season the AKC and AKC CAR also collected and donated nearly $1 million to assist in the recovery of pets in the affected area. For more information about the AKC CAR visit the web site www.akccar.org.

The AKC and AKC Companion Animal Recovery (AKC CAR) filed comments on September 6, 2006 with the…