Comment from Martha H DeWees, DVM, McKenzie Animal Hospital

In reference to the section in quotes at the end of my comments: Having experience with microchipping pets in my practice for more than 20 years, I believe it is also important to include the requirement that all chips manufactured to a new standard also be required to have the non-migrating characteristic as does the Home Again chip. The AVID chip does not have this feature and must be implanted deep into the fascia attached to the dorsal spinous process of the thoracic vertebrae to minimize migration (as stated on the AVID package insert). This procedureis painful for most pets and if not done properly, will allow the chip to slide along tissue planes and relocate anywhere along the sides, belly and down the forelegs. This will result in some chips not being found on the scan because the chip is implanted on the dorsal midline cranial to the shoulder blades. I have not read about this concern and wanted to be sure that you consider this in any rules you promulgate. Thank you. "In light of the conference committee report and petition set out above, APHIS is now considering amending Sec. Sec. 2.38 and 2.50 to add ISO 11784 and 11785 compliant radio frequency microchips as an official means of identifying dogs and cats by research facilities, dealers, and exhibitors. ISO 11784 (which relates to the code for identification) and 11785 (which relates to the technical operations between the code and reader) are international standards that specify the structure of the radio-frequency (RF) identification method for animals. RF identification of animals requires that the bits transmitted by a transponder are interpretable by a transceiver. Any producers of identification devices that wish to manufacture compliant microchips would have to acquire the standard from ISO; APHIS cannot itself provide the standards to manufacturers."