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An Analysis of the USDA Horse Protection Enforcement Report

Posted February 13, 2002
© 2002, Walking Horse Report. No duplication without written consent. All Rights Reserved.
The following analysis of the United States Department of Agriculture Horse Protection Report for the calendar year 2000 was prepared by Craig Evans and outlines some of the fallacies of the reports conclusions.

The analysis was prepared for the members of the National Horse Show Commission and the Tennessee Walking Horse Breeders' and Exhibitors' Association executive committee.


The USDA Horse Protection Report ("Report") has recently been released. The Horse Protection Act ("HPA") requires that the Department provide this report to Congress each year. It is a compilation of the figures garnered from the various Horse Industry Organizations ("HIO's") with certified Designated Qualified Person ("DQP") programs.

The Report delineates a disparity between reported violations when USDA Veterinarian Medical Officers ("VMO's") are present and when only HIO DQP's are present. Historically, the disparity has been a minor source of inquiry usually explained by challenging the presumption that had the VMO's not been present the violations would not have been reported, and by pointing out that VMO's only attend highly competitive events while HIO's attend many that are not, but the horses inspected at non or less competitive events add to the total number inspected and thereby dilute the percentage of reported violations.

However, while we continue to espouse the "regulate the regulators" as the program we want the Secretary to pursue, and while the American Horse Protection Association has a suit pending against the USDA contending that the USDA has illegally abdicated their position of authority and HIO's are doing a poor to non-existent job of enforcing the HPA, we can expect to be challenged far more vigorously on the disparity as evidenced by the recent Associated Press wire inquiry.

Consequently , the following is an outline explaining my understanding of the disparity. As I can attest, the obvious risk in providing a lengthy detailed response, is that the press may well pick one or two lines out of context and report only those. But, I believe that risk to be less costly than to simply run and hide and I assure you that the inquiry is already being made by Senators and Congressman that are sympathetic to our cause and therefore I submit that it must be answered

1. It took fourteen months to prepare a Report that should have taken fourteen days, which speaks volumes about the ability of the USDA to respond to a changing industry and to effectively administer the HPA. The HIO's are far more responsive and effective as demonstrated by the NHSC's use of fluoroscopes and then hoof testers in response to a perceived threat.

2. There is an unstated inference that had VMO's not been present, certain violations would not have been reported, which is not accurate and can not be substantiated.

3. In arriving at the reported violations percentages, there is no differentiation between reported violations of "sore" horses and technical violations such as a band that was 1/16th of an inch high, or foreign substance such as baby powder on a horse's pastern, or spray on the upper leg over an abrasion. There is a bar graph near the end of the report which purports to separate out the bilateral sore horse and it appears that the disparity there is 4 to 1 as opposed to 16 to 1.

4. There is no differentiation between competitive events and non gait-competitive events, exhibitions, conformation events, mare and foal in hand events, weanling and yearling futurities etc., etc. The VMO's appear at the largest and most competitive events and the percentages of reported violations at those events with VMO's present should only be compared to similar large competitive events when the VMO's are not present. For instance, the NHSC inspects the mare and foal at Equitana every day and inspects a host of versatility events, all without VMO's present, and those inspections are added to the total NHSC inspections which dilutes the percentage of reported violations at gait-competitive events.

5. There is no differentiation between the period of January to August of 2000 when the USDA was attempting to coerce our execution of an Operating Plan, versus that period after the Operating Plan was signed after the USDA offered it's "Letter of Clarification".

6. There is no accounting for the eleven out of twenty-six conflict resolution cases in which the USDA conceded that the VMO's were wrong. It is not just as fair to extrapolate that data to project a VMO incorrect diagnosis percentage of forty-two percent (42%).

7. There is no accounting for which one or two VMO's may have been the prime reporters of violations and why they might differ in their individual percentages from the other VMO's. With that accounting, would it not be just as fair to conclude that one or two VMO's were biased if their percentages were disparate from others, or instead would one conclude that the rest of the VMO's were simply incompetent.

8. There is no accounting for the facts contained near the end of the report that indicate Investigative Enforcement Services ("IES") investigated ninety-seven VMO reported violations but only sixty-four complaints were issued. Is it not fair to extrapolate that data to project that thirty-five percent (35%) of the VMO reported violations are in error and what effect would that have on the disparity of percentages.

9. Are there a sufficient number of comparable event to arrive at a statistically significant conclusion. I submit not.

10. All of the foregoing reveals the difficulty of interpreting a summery of data. Without the raw data, which has not been released to the HIO's, and the correct application of statistical theorems, the numbers are just numbers without meaning. The extrapolations I have suggested may be as unfair as those suggested by others. The appropriate method of finding meaning is to compare similar events under similar conditions at similar times in large enough numbers to arrive at a statistically accurate conclusion.

I regret that Nancy Zuckerbrod, the AP wire reporter, failed to appropriately report even the tenor of our interview, and instead, for reasons known only to her, chose to omit the vast majority of our forty-five minute interview and focus on one statement taken out of context and in response to a different question.

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