The American and International Associations of Professional Farriers and the American Horse Council publicly announced their stances on the proposed amendments to the Horse Protection Act by the United States Department of Agriculture’s Animal and Plant Health Inspection Service.
Here is the full text of the AAPF’s position that has been submitted to APHIS.
September 27, 2016
Docket No. APHIS-2011-0009
Regulatory Analysis and Development, PPD
4700 River Road, Unit 118
Riverdale, MD 20737-1238
To Whom it May Concern:
In January 2012 a new farrier association was launched – the American Association of Professional Farriers Inc. (AAPF) (and thereafter, sister organizations – the Canadian Association of Professional Farriers and International Association of Professional Farriers). It was determined that the foundation of these new associations would rest on knowing that farriers would be recognized based upon his or her accomplishments as a professional. Further, the associations will promote the integrity of the farrier industry by strengthening the knowledge and skills of its members through the promotion of continuing education opportunities, while improving overall equine health through collaboration with other industry professionals. Today the association has over 800 members through the United States.
The AAPF Board of Directors has unanimously agreed to support the position of the American Horse Council, as well as our Alliance member – the American Saddlebred Horse Association – in relation to the proposal to amend the horse protection regulations.
Like the American Horse Council, the AAPF has always opposed soring of horses and supports the enforcement of the HPA. We emphatically agree that soring is an abusive practice and should not be tolerated. Unfortunately, the practice of soring continues in the Tennessee Walking Horse, Racking Horse and Spotted Saddle Horse industries.
Improvements to the HPA enforcement program are clearly warranted. However, while supporting the need to enhance the enforcement program for these specific and identified equine industries, we are adamantly against any rule or regulation which would adversely impact or unnecessarily burden other segments of the horse show industry that are not soring horses and have demonstrated no history of soring horses.
Additionally, we are concerned that any rule or sub-section which does not specifically address the Tennessee Walking Horse, Racking Horse or Spotted Saddle Horse industry, could run the risk of legal interpretation to include other segments of the horse show industry.
Your clarification would be appreciated.
Steve Prescott CJF APF
2016 – 2017 President
Here is the full text of the American Horse Council’s position.
AHC Statement on Proposed Horse Protection Act Regulations
Many individuals in the horse industry are aware that the U.S. Department of Agriculture’s (USDA) Animal and Plant Health Inspection Service (APHIS) has published proposed changes to the regulations governing enforcement of the Horse Protection Act (HPA). The proposed rule would make several major changes to current HPA regulations with the goal of ending soring, including a new licensing program for HPA inspectors and a ban on action devices, pads, weighted shoes and foreign substances at walking horse shows, exhibitions, sales, and auctions.
The American Horse Council (AHC) strongly opposes soring and believes action must be taken to stop the soring of “big lick” Tennessee Walking Horses, Racking Horses and Spotted Saddle Horses. However, the AHC is concerned that certain provisions of the proposed rule are too broadly written, not sufficiently defined, and could cause confusion for the horse show industry. Like all industries, the horse show industry requires clarity in any regulatory regime that impacts its operation. Soring is a problem that is well defined and limited to a very specific segment of the walking horse industry and any new regulations should reflect this fact.
The AHC’s formal comments to USDA will strongly urge USDA to explicitly limit all new provisions to Tennessee Walking Horses, Racking Horses, and Spotted Saddle Horses, mirroring the PAST Act. Making this change will address most concerns the horse industry has with the proposed rule and will fulfill the purpose and intent of the HPA.
The AHC wants to be clear, many of the proposed changes to the HPA regulations are needed, such as replacing the ineffective Designated Qualified Person (DQP) program with a new independent inspection program. Additionally, because of a long history of utilizing action devices, stacks, weighted shoes, and foreign substances to sore horses, a ban of these items on Tennessee Walking Horses, Racking Horses, and Spotted Saddle Horses is justified and needed.
However, the AHC believes it is equally important that any new regulations be narrowly focused on the problem of soring and do not inadvertently impact or unnecessarily burden other segments of the horse show industry that have no history of soring horses.
The AHC will be submitting detailed written comments to USDA in the coming weeks.
The USDA has extended its public comment period regarding the proposed HPA amendments to Oct. 26, 2016. To voice your support or opposition, visit http://www.regulations.gov/comment?D=APHIS-2011-0009-0001