2004N-0049 - Agency Information Collection Activities; Proposed Collection; Comment Request; Control of Communicable Diseases; Restrictions on African Rodents, Prairie Dogs, and Certain Other Animals
FDA Comment Number : EC39
Submitter : Mrs. Gena Seaberg Date & Time: 04/08/2004 03:04:14
Organization : Consultant for Captive Pet Prairie Dog Care
Category :
Issue Areas/Comments
Part one of two email comments, both documents referenced are attached to this message. Hard copy mailed March 27, 2004. As a voter, tax payer, animal lover, and consumer, I have a few comments and suggestions in response to the above referenced docket as well as a few questions that I kindly request a response. To date the offices of the FDA and CDC have not responded to my original comments to Docket No. 2003N-0400. Since the docket above pertains to information collection, I am wondering why there are no responses or comments from both offices to people?s requests for information and response to add to this data collection process? My letter contained many logical arguments that have been ignored, side-stepped, and left unanswered by the FDA and CDC, why? I would like to request immediate written response to my comments dated November 8, 2003 and January 6, 2004 as it pertains to Docket No. 2003N-0400 to add to this information collection period for this docket. These answers are critical in demonstrating the poor logic being applied as it pertains to making this proposed ban permanent.
Upon calling the offices of the CDC and FDA about the matter, I have not gotten any answers to my questions either, why? When asked why the importation of animals and quarantine measures are not being addressed as the ultimate underlying issue pertaining to the proposed ban, I still have not gotten an answer. Prairie dogs do not inherently carry monkey pox, the sylvatic plague, or tularemia. They only contract the illness from infected fleas, or other infected animals. Other rodents, including rats, rabbits, hamsters, guinea pigs, gerbils and other common household pets could contract the same disease but only if they are exposed to it, the same as the prairie dog. What is the FDA and CDC going to do when another disease outbreak occurs due to improper handling during importation and quarantine and the animals are exposed to these more routine pets? Again, why isn?t this the true issue of the matter at hand than the banning of prairie dogs and other African Rodents? What has the FDA and CDC done to preserve the native prairie dog when putting this ban in place? It is common knowledge that the species is truly declining as we speak due to development. Many of these animals have been given another chance at life as pets instead of being bulldozed, poisoned, shot or worse. What have both agencies done with this ban to ensure animal welfare and the preservation of one of our keystone prairie species? From my communications with both agencies, there has been the argument that there is no substantive clinical data to document how vectoring or harboring of MPV occurs in prairie dogs and due to lack of data is why the ban may not be lifted. Since the last infected prairie dog to die of MPV occurred in July of 2003, again, please answer why no one else, including pet prairie dogs, have contracted MPV during the past eight months? According to common logic, how would the public or any scientist be able to prove a negative? Monkeypox is no longer an issue and I thank both agencies for their quick response in limiting the outbreak to only 35 human laboratory confirmed cases. But, with no prairie dogs infecting others, how can anyone prove the threat is still an issue? You would think that if prairie dogs were harboring MPV, we would still see some cases in the past eight months. Please answer how this won?t occur again with other imported animals in the future and if it won?t, why are our native species being banned and not all species that could contact this illness? Again, there is inherent risk to anything in life, including pet ownership. I will ask again, there are other known zoonotic illnesses associated with other pets, yet why are they not being banned? Please answer how both agencies are equitably applying there logic with this ban? I can contract illness from different reptiles, avian species and felines yet they are not being banned, why?