Skip to content

AHC Comments on Pads and Chains



Editor’s Note: The following letter was submitted by The American Horse Council and its President James J. Hickey, Jr. on April 30, 2012 to the USDA in response to the HPA listening sessions.

Click here to view the letter in PDF format.


April 30, 2012
 
Dr. Rachel Cezar
Horse Protection Coordinator
4700 River Road, Suite 6D03
Rockville, MD 20737
 
Re:  USDA-APHIS: Horse Protection Program Listening Sessions
 
Dear Dr. Cezar:
 
The American Horse Council (AHC) appreciates the opportunity to submit these comments to the U.S. Department of Agriculture (USDA), Animal and Plant Health Inspection Service (APHIS), pursuant to the recently-completed listening sessions APHIS’ Animal Care Program held throughout the U.S. to obtain feedback on the Horse Protection Program.  The AHC supports APHIS’ efforts to strengthen enforcement of the Horse Protection Act (HPA).  The AHC opposes any practice that might cause pain or distress to any horse under the HPA.  
 
American Horse Council
 
The AHC is a Washington-based association that represents individual members and over 120 equine organizations before Congress and the federal regulatory agencies.  AHC member organizations include breed registries, national and state equine associations, state horse councils, recreational associations, and organizations representing race tracks, horsemen, horse shows, veterinarians, farriers, rodeos, and other equine related stakeholders. The AHC also includes individual horse owners and breeders, veterinarians, farriers, trainers, professional, amateur, and recreational riders, and commercial suppliers.  Individually, and through our organizational members, the AHC represents several hundred thousand horse owners and others involved in all sectors of the horse industry.
 
APHIS’ Questions of Interest
 
Prior to the HPA listening sessions, APHIS published a list of questions the Agency was particularly interested in receiving feedback on from stakeholders.  The AHC’s comments are limited to addressing and responding to the following questions APHIS put forward in the context of how they might affect various breeds, shows, exhibits and activities that fall under the HPA.
 
• Should there be a prohibition of all action devices?
• Should there be a prohibition of pads? 
 
Action Devices and Pads
 
The AHC does not support an outright prohibition of all action devices or pads.  A complete prohibition could result in unintended consequences that may not be in the best interest of the horse, various regulated breeds or various regulated exhibitors, shows or exhibitions. 
 
Some devices and pads are used by a variety of breeds for the protection of the horse during showing and training.  For example, certain devices, which may fit within the technical definition of “action devices” under the regulations, are used by certain breeds to protect a horse’s foot or to prevent over-striding.  Additionally, a simple prohibition of all pads could adversely affect certain breeds that use them for legitimate purposes for the protection of the horse’s feet and limbs.  Pads may serve several legitimate needs, such as:
 
• To protect the hoof from abrasions or penetration on hard or uneven surfaces;
• To provide a cushioning agent for the hoof and limb when working or showing surfaces are unduly hard or rough;
• To maintain the natural angle of the foot and pastern;
• To compensate for conformational abnormalities of the foot and limb;
• To aid in keeping the shoes intact on horses with thin-walled or brittle feet;
• To permit the use of packing under the pad to maintain proper softness and flexibility of the hoof;
• To protect the foot from the development of septic processes;
• To facilitate the application of therapeutic medication to the hoof;
• To increase or decrease support to the foot and limb as an aid in the treatment of lameness; and
• To build up the proper matching length and angle of any foot that has been broken or damaged. 
 
Pads used in these ways are applied in such a manner as to maintain or achieve appropriate hoof-pastern axis.  Pads and other devices are used by a number of breeds and exhibitors in a protective or beneficial manner and are in the best interest of the horse’s health and soundness.  
 
USDA should not implement a complete prohibition of all pads and action devices for all breeds and disciplines.  Furthermore, any consideration to prohibit the use of pads or actions devices should be based on sound science and considered only after a full, public rulemaking process.  For these reasons, in response to the two questions noted above, the AHC feels that the use of pads and other devices should not be banned outright.
 
Conclusion
 
The AHC opposes any practice that might cause pain or distress to any horse under the HPA.  The AHC does not condone any segment of the horse industry using action devices or pads in a manner that is not in the best interest of the horse.  Furthermore, the AHC opposes any use of any action devices or pads that may result in the infliction of pain or discomfort for the horse, but the AHC does not support an outright prohibition of all action devices or pads because, in many cases, the use of pads or devices may be beneficial.   Moreover, an outright ban on action devices or pads could have unintended consequences for some breeds, shows, exhibitions, or exhibitors.
 
The AHC considers the safety, welfare, and what is in the best interest of the horse to be the paramount consideration in administering and implementing the HPA.  The AHC encourages USDA to continue to incorporate transparency and collaboration in all HPA initiatives and urges the Agency to work cooperatively with stakeholders to ensure the horse industry thrives while also eliminating the act of soring.
 
Thank you for the opportunity to submit these comments.  If you have any questions or need additional information, please contact us.  
  
 
      Sincerely,   
                       

      James J. Hickey, Jr. 
      President

More Stories

  • **Updated Horse Show Schedule

    The Walking Horse Report will provide daily updates to the list of canceled and postponed horse shows... Read More
  • Latest Issue 11 2 20

    Read More
  • Incentives added to Fall Classic’s Debut Two-Year-Old class

    The Celebration Fall Classic had added incentives to the winner of the $1000 Debut Two-Year-Old Walking Horses class on the Saturday night show schedule. The new class is for any two-year-old that has not previously shown in 2020. Read More
  • Notice WHTA Members

    The 2020 WHTA Nominating Committee is composed of Brad Beard (Chairman), Jessica Hlebak and Russ Thompson. Anyone wishing his or her name be added as a candidate will need to notify the WHTA office or a member of the Nominating Committee no later than November 9, 2019 his or her intent to run for an officer or directorship... Read More
  • Updated venue for Saturday meeting

    The Walking Horse Trainers' Association's open meeting Saturday at 1:00PM has been moved to the main area of Calsonic Arena. The move is to allow for social distancing and the WHTA strongly encourages everyone to wear a mask at the meeting. Read More
  • Equine Obituary – Gen's Lady Topaz

    Gen’s Lady Topaz was humanely laid to rest on October 24th, 2020, just one week shy of her 27th birthday. She was one of only a handful of direct Pride’s Generator mares left. Gen's Lady Topaz was the matriarch of Rushing Creek Walker’s breeding program for many years and the ambassador to any visitors. Read More
  • Walking For The Angels revises class schedule

    The Walking For The Angels Horse Show, scheduled for Saturday, November 14, has added several classes to their original schedule... Read More
  • FAST Showcase revises class schedule

    The FAST Showcase, scheduled for Friday, November 13, has added three classes to their original schedule... Read More
  • WHTA to host open meeting October 31st

    The Walking Horse Trainers’ Association will host an open meeting on Saturday October 31st at 1:00PM at the Hall of Fame in Calsonic Arena. The meeting will be to present details on the proposed legislative amendments and have questions from industry participants answered.  Read More
  • Obituary – John Peels

    Mr. John Luther Peels, age 84, of Shelbyville, passed away Sunday, October 25, 2020, at his home under the loving care and comfort of his family and Willow Brook Hospice... Read More