This is my report from the Animal Transportation Association sponsored webinar on July 8, 2013, with Dr. Jeleen Briscoe from USDA APHIS Animal Care Emergency Programs. She was speaking on the final rule requiring contingency plans for regulated transport of animals that are covered by USDA.
While most horses don’t fall into this category, there are some that do and there are many businesses (veterinary, transportation, show management, boarding facilities, breeding farms, etc.) that house and transport horses that would benefit from following these suggestions.
Since all types of facilities and transportation can be affected by emergencies and disasters, an All Hazard emergency response plan is highly suggested for any facility.
For certain USDA-APHIS-regulated facilities and animals such as circuses, zoos, research facilities, etc. those affected are now required to develop a contingency plan for disasters and emergencies.
The APHIS Definition of a Contingency Plan (CP) is “A plan to improve animal welfare by responding to and recovering from emergencies,” also called an “Emergency Plan” by some people. Derived out of Hurricane Katrina lessons learned – for regulated animals like the zoos and aquariums that were evacuated (or not) – we all learned that proper planning benefits animal welfare and is a collaborative process.
Simply put, a CP means that there should be a plan for ensuring that animals have water, shelter, food, and protection from harm or euthanasia in the event of disaster. Can you do that in your barn, clinic, or animal handling facility? Does every employee know what to do? Better planning equals better resistance to harm and resiliency which translates to better animal welfare.
Did you know that over 65% of small businesses do not have a CP for people, much less for animals? But the planning component is the most important part of the process. It is not sustainable to think “it won’t happen to me.” It can happen to anyone.
The regulation effective date is Jan. 30, 2013, the final rule (77 FR 76814-76824) was published Dec. 31, 2012, in the Federal Register and establishes "regulations under which research facilities and dealers, exhibitors, intermediate handlers, and carriers must meet certain requirements for contingency planning and training of personnel." CP must have been in place by July 29, 2013, and the facility CP can be inspected by Sept. 27, 2013. Human safety has to take precedence over animals in the planning.
All AWA licensees and registrants under USDA have to have a CP, they must document their staff training, and they must perform an annual review of the CP. There is no standard format or template or requirement to evaluate the plan or for submission to APHIS. Holding facilities that are pre-approved to hold animals will be included in this regulation. Traveling entities must carry a copy of their part of the plan on the road or in the air with animals that are covered.
A good CP should answer these basic ideas:
- When will you activate the plan? What emergencies would be likely to happen in your region and type of business? Fire? Flood? Power blackout?
- What will you do? What specific tasks must be completed to carry the plan out? Employee confusion about their roles in an emergency has been identified in the past as a huge obstacle and can be overcome by including staff in the development of the CP.
- Who is in charge? The chain of command must be identified by name or position so that turn over of employees does not effect it.
- How will you get it done? What materials, resources and training are needed?
At there is a web page with all the information and links to resources (Zoo Animal Health Network, FEMA, Agility and US Small Business Administration), National AG library, USGS) and including a public webinar on the ruling in February.
Questions and Answers
Q: Do I have to carry a copy of my plan?
A: Yes. Might be a small part of the plan, but even the driver needs to know their part of the plan.
Q: Who needs to be trained on the plan?
A: All employees need to be trained, the goal for anyone that handles or cares for animals or handles employment issues should have their role defined.
Q: How to cross-reference other plans in the transport chain for animals?
This is an ongoing challenge. APHIS will try to give clearer guidance for transportation facilities and intermediate handlers, developing training tools and additional guidance materials.
Template? None is available or required at this time.
Q: Who to call in cases of emergencies?
A; They are working on this at APHIS. You should know locally who to call for help (veterinarians, 911 emergency responders, etc.).
Q: Where can these be stored and share this information?
A: This is an ongoing challenge and we don’t have the answers right now.
Remember, readiness for emergencies is empowering.
Editor's Note: On July 31, APHIS issued a stay of the contingency plan regulation in order to give the agency additional time to determine how best to address the range of unique circumstances facing regulated entities, from small to large, and how to better communicate about these potential impacts and expectations. There is no planned length of time for the stay of this regulation.
Additionally, while APHIS is no longer requiring that licensees have a contingency plan in place at this time, the group encourages licensees to develop a contingency plan and if they would like assistance, an inspector is available.