Domestic rabbits are NOT dogs, and it's time the Health Dept of New Jersey recognize that. After taking multiple complaints from persons hiding behind fake names and annonymous complaints from people who have never actually been inside the rescue, the New Jersey Dept of Health has been unfairly bullying Little Miracles staff; by showing up outside business hours, and expecting us to accommodate them regardless. They interview children and teenage volunteers during their inspection, expecting them to properly explain in detail the shelter's cleaning procedures rather than reading our SOP and speaking to the adult staff.
After taking multiple complaints from persons hiding behind fake names and annonymous complaints from people who have never actually been inside the rescue, the New Jersey Dept of Health has been unfairly bullying Little Miracles staff; by showing up outside our designated business hours and demanding our volunteer staff to accommodate them, inspectors have taken advantage of the small no-kill rescue by entering the facility, splitting up and wandering around the building, asking volunteers as young as 11 to explain in detail record-keeping, cleaning procedures and more, and then taking answers from these kids as the "official" answers on behalf of the shelter, rather than speaking to adult volunteer supervisors.
The Health Dept of NJ and Camden County both inspected and passed Little Miracles shelter in July 2011. In Spring 2012, Little Miracles was inspected again and given a short list of things to correct to finish inspection; 1) Have our new vet sign off on our policies for animal segregation and our isolation room design. 2) Get a new copy of our fire inspection posted because our 2011 certificate was missing and 3) Hire someone to cut back the tall grass near the dumpster and in the back yard. All these things were corrected, and 5 weeks later the county inspector came back with the state inspectors - this time making a list of over 30 demands for changes to the building, the facilities, the animal's housing, the layout of all the shelter's rooms, lighting, plumbing, ventilation for the washer/dryer and more -all things that had not changed since the shelter had passed inspection the year prior.
Many of the Health Department's new demands involve the inspectors enforcing their opinions rather than the law. They have ignored federal regulations set forth by the USDA that outline care specifically for rabbits, rodents and other small pets - for example, that water recepticles shall be kept clean, per the USDA, and the bottles sanitized once every two weeks. The NJ Health Dept is demanding we remove, wash and sanitize 110 rabbit water bottles daily.
The federal government says that rabbits who live on solid floors (as they should for protection of their sensitive feet) should have their cage spot-cleaned as needed to prevent "the excessive buildup of excretia" and litter boxes should be changed at least once per week. The NJ Dept of Health wants rabbits to stand on wire floors so they don't come in contact with any bunny poo. They want us to eliminate the use of litter boxes, or change, wash and sanitize every litter pan AND sweep, mop with cleaner, rinse, mop with sanitizer and dry every single litter pan and every single cage, every single day, citing that 24 hours worth of bunny poo is "excessive". They photographed cages with less than 24 hours of waste, and stated that it was excessive and documented that we do not clean cages daily, which is entirely untrue. We spotclean, vacuum, sweep, and wash cages regularly, working on every cage as needed.
The investgators are not rabbit people. They do not understand that rabbits are not cats or dogs who poop once a day, and who's kennel cleaning must be done every single day. The inspectors have taken advantage of the small no-kill rescue, bullying us in an aggressive and unfair way.
In addition to wanting us to eliminate solid bottomed cages and litter boxes, which emulate the environment we want for our pets once adopted, the NJ Dept of Health wants us to expose the rabbits to the harmful fumes and effects of bleach by keeping their living environments sterile.
The NJ Health Dept has stated that hay should not be allowed in their litter pans where it may become soiled, and wrongfully stated in inspection reports that animals were "not fed daily" because our current schedule gives our rabbits pellets and touch-up hay on even date days, and hay and fresh veggies on odd days; a diet that keeps our rabbits healthy and at a good weight, as is proven by health records of all our animals. The Dept of Health wants us to give the rabbits pelleted food every day - a diet that affects rabbit's weight negatively, causing them to become excessively overweight. They even demanded we store hay in "airtight containers" to keep out sunlight, bugs, fur or other contaminants. Keeping hay in such a manner is dangerous and can easily cause mold and mildew that can be lethal to animals ingesting it. We want the Dept of Health to recognize the standards of care set forth by the USDA and stop trying to enforce laws designed for dogs on a rabbit shelter. Rabbits NEED hay in their litter pans, to eat while they "do their business". Unlike dogs, cats and even humans who keep our food far away from waste areas, rabbits associate their hay with their potty break. Our shelter provides fresh hay for them to eat so that it is available in abundance at all times - don't let the health department force us into removing hay from their litter pans or force us to store hay in an unsafe manner!
The Dept of Health has said that no shelter is allowed to exercise animals in supervised outdoor areas, unless the area is sealed concrete. Our current exercise areas allow rabbits to nibble fresh grass, untainted by chemicals, to dig in natural dirt and sand that is contained and protected to allow for play and instinctual digging but doesn't permit escape. Other area shelters such as Animal Orphanage, Camden County Animal Shelter, Animal Welfare Association and more have fenced in yards with which to exercise animals, but the Dept of Health is trying to deny our pets fresh air and natural exercise areas that all the other shelters have, citing that we need to pour concrete slabs and paint/seal them, even though the law states that only "PRIMARY ENCLOSURES" must be designed with surfaces that are impervious to moisture, which is where an animal lives, not where they exercise. Lynn, inspector for the state went so far as to say that shelters can walk dogs on leashes on the grass, but not allow them to run freely in yards, stating that on a leash, staff can "prevent the cross contamination by diseases". It makes NO sense. Why are they attempting to enforce their opinions rather than statute? Why are they passing other area shelters with outdoor play yards, yet bullying us into removing ours?
Tell the NJ Health Department to have respect for animal welfare organizations and to look to federal standards of care designed for RABBIT CARE and not for statue designed for DOGS. Tell them that you are a rabbit lover, and that rabbits eat cecotropes (one of two kinds of feces they produce). That properly stored hay (in a cool, dry open-air area) is essential, and that rabbits NEED hay available in their litter pans. That rabbits don't deserve restrictive spaces on wire floors that separate them from their waste - that litter training and solid floors are safer and healthier and that federal regulations require once weekly litter changes which we already exceed, but that daily litter changes is unrealistic and unnecessary. Tell them that rabbits need not be exposed to harsh bleach and chemicals regularly (we currently bleach between occupants, and only use bleach regularly for sick-bunny cages). Tell them that there are healthier and safer solutions, such as enzyme cleaners and natural substances. Tell them that rabbits diets should be the decision of our veterinary and medical staff, and not based on their unrealistic assumption that rabbits should eat like dogs, with kibble twice daily!
Demand that the NJ Health Department stop inspecting outside our hours of operation, that they stop wandering around multiple areas of our building, not allowing our staff to accompany them while they take photographs and interrogate junior volunteers. During their first visit of 2012, an inspector from the state was drilling an 11 year old girl volunteer who was spot-cleaning cages, and asked her to explain the entire cleaning process. The inspector then included in her report that the staff was improperly cleaning based on the nervous 11 year old's answers AND then humiliated the 11 year old, stating in front of all the staff and investigators that the child had sprayed cleaner (pet safe enzyme cleaner) "in the vicinity of the rabbit, without removing the rabbit from its enclosure while she wiped down the cage walls exposing the rabbit to harmful chemicals", causing the little girl to break down in tears!
The inspectors have demanded dozens of files, all of which were provided promptly, and insinuated that rabbits who were being surrendered as stray were mistakingly being admitted as being owned animals, because our shelter determines that if an animal was found outdoors and then kept for a period of weeks, months or years, that the animal was no longer a stray and asked the surrenderer to fill out the surrener form. The health department says no; regardless of how long a person has had a rabbit, if they found it outdoors, it's still a stray and must go to the county shelter to be isolated for rabies, rather than being allowed to come to our no-kill shelter. They told us to stop accepting stray rabbits because the county has to accept them, even if they intend to euthanize them, because they need to watch all rabbits for rabies!
Tell the NJ Dept of Health to stop nit-picking Little Miracles due to the false and anonymous complaints they've recieved a small number of our harassers. Tell them that rabbits are NOT dogs, and that our standards of care, based on (and typically in excess of) the USDA's standards, which include daily spot cleaning, twice weekly litter changes, bi-weekly sanitation of water bottles, weekly food dish cleaning, healthy low-pellet diets full of fresh hay and fresh veggies, and healthy outdoor play and exercise that allows our rabbits to BE RABBITS, are not only acceptable but ideal.
We want a fair inspection; that we are held to the same standards of other area shelters, and that our care is looked at as it applies to rabbits, and not that of dogs. Tell them to stop bullying our staff -inspect during our open hours AFTER we-e done the daily cleaning, rather than showing up before the staff has a chance to open for the day. Demand that they stop holding us up with 3-4 hour inspections, during which staff has to be stopped from cleaning and feeding because investigators interrogate even the children who are working. Stop badgering 11, 12 and 15 year old volunteers demanding answers about our operations, and speak to our administration when you have questions about how things are done! Stop accepting lies and false anonymous complaints from harassers that have never even been inside our facility, demand proof that complaints are legitimate before repeatedly harassing our shelter with excessively detailed inspections - its clear that the health department is acting on a personal grudge against our shelter's president. Stop demanding our shelter obtain "kennel licenses" that are only applicable to dog facilities. Its not within the statute and we shouldn't be coerced.
We obtained and operated under a business permit for the township for 2011, but than in 2012 are being told we need to obtain a shelter permit. The township doesn't even have or understand what the Health Dept wants, and the Health Department is holding the township's procedures against us!
NJ Dept of Health: Leave Little Miracles alone. Let us continue saving lives and stop disregarding the realistic needs and concerns for care as it applies to the animals we care for! Rabbits and rodents are NOT DOGS, and we should be following guidelines designed for RABBITS. Give Little Miracles time to work on the construction and improvements that are realistic, while allowing us to continuing our daily operations, and reconsider the unrealistic elements of the inspection that don't apply to our type of shelter. We save over 500 lives each year, and New Jersey, its residents and its animals need us.
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