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APHIS Docket Office
ATTN Docket No. APHIS-2006-0012
Regulatory Analysis and Development
PPD, APHIS
Station 3A-03.8
4700 River Road
Unit 118
Riverdale, MD 20737-1238
RE: Microchips (Docket No. APHIS 2006-0012)
Dear Docket Office:
I am one of the millions of dog owners who have had their dogs microchipped with the 125 chip because of the proven track record of the 125 microchip infrastructure in the U.S., which has been responsible for the recovery and return of thousands of dogs to their thankful owners. “Proven track record” bears repeating!!! That is why I respectfully urge APHIS to proactively resist the efforts and pressure it is under to support, directly or indirectly, a transition to the exclusive or “dual use” of the ISO 134 microchip. I further believe that such a transition would be reckless and irresponsible for the following four reasons.
First, those who advocate the exclusive or dual use of the ISO 134 microchip have made unsubstantiated statements that the existing 125 microchip is a failure. Those statements are not only unsubstantiated, but they distort the fact that thousands of lost dogs have avoided the tragic fate of being euthanized, and have been returned to their thankful owners because they were successfully scanned with a 125 scanner.
Second, additional unsubstantiated representations have been made about the accuracy of the so-called “universal scanner.” Those representations should be validated and documented because they are being made by some who stand to make millions of dollars without regard to whether thousand of dogs with the 125 microchip may inadvertently be euthanized because of the “failure” of the universal scanner to identify either the 125 chip, or even the 134 chip - - the worst of all possible worlds! Such a potential consequence would be a grotesque desecration of the spirit and intent of Animal Welfare Act which APHIS is charged with the responsibility to implement and enforce. Please exercise that responsibility with loving care for the dogs that could become innocent victims of a rush to a technology that is not here yet.
Third, it is absurd to suggest that just because the ISO 134 microchip is used for cows and horses, it should be used for dogs. Dogs are not “livestock.” Dogs are kept in the comfort of their owners’ homes. Cows and horses rarely, if ever, have spent the night inside the home and personal living quarters of their owners. That is a fact that APHIS should never, ever ignore.
Fourth, in an era of ever increasing “identity theft,” extraordinary care should be exercised in safeguarding the personal data of pet owners, and ensuring that the release of personal information that is protected by the Privacy Act is not subject to indiscriminate release. Many of those who are advocating the transition to the exclusive or dual use of the ISO 134 microchip have conveniently ignored the fundamental rights of pet owners, and those rights will be further violated if a rush to adopt a uniform data bank is haphazardly developed, misused or not properly safeguarded.
In closing, the 125 system works, and has become increasing more successful each year as more and more responsible pet owners have their dogs micrchipped with the 125 chip. That is why APHIS must “DO NO HARM” when it makes any recommendation to Congress, or elects to change any of its policies or regulations with regard to the continued use of the 125 microchip
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APHIS Docket Office