Tiny Turtles at Cold Blooded Expo

We Moved FDA to Help Tiny Turtles!



Following a year-long investigation and more than six months of behind-the-scenes campaigning, federal authorities have finally moved to stop the apparent sale of illegal turtles by three of the country’s most prolific reptile expos.

After a meeting with World Animal Protection last week, the US Food and Drug Administration (FDA) accepted our evidence. It indicated that it would demand the owners of Cold Blooded Expos, Repticon, and HERPS, move to prevent the apparently illegal sales. 

Turtles with shells less than four inches in length are illegal to sell because children are more likely to put them in their mouths or touch them and then put their hands in their mouths without washing them. Children under five account for around half of the country’s approximately 74,000 reptile and amphibian-associated salmonellosis cases every year—yet in a sick irony, this is precisely the age group that these three reptile expo companies let into their events for free

The regulation banning the sale of tiny turtles (21CFR1240.62) falls under the 1975 Public Health Services Act. The FDA enforces it—despite turtles being neither a “food” nor “drug”—with the help of state health agencies. It is perhaps a result of the peculiar placement of enforcement responsibility with FDA and not CDC or FWS that has allowed the sale of tiny turtles to go unchecked for so long. World Animal Protection’s experience dealing with local health authorities also explains why enforcement would be patchy (credit to authorities in Florida, Oklahoma, South Carolina, and Kansas for their attempts to prevent reptile-born Salmonella infections in their states). 

Despite hundreds of millions of dollars from the American Rescue Plan recently flowing into federal agencies for tackling the illegal wildlife trade and monitoring susceptible animals for diseases, no funding appears to have been earmarked to help ease the significant backlog and burden placed on the FDA of enforcing the 1975 ban on tiny turtles.  

Sulcata Tortoise

A tiny turtle at a reptile expo in Bloomington, Minnesota

Why does an animal welfare organization care about human disease? 

Well, for one, we have a heart. During our investigation into the horrendous conditions for snakes, lizards, turtles, and other reptiles at exotic pet shows, we discovered that enforcement of public health concerns was lax, to say the least: Touching of animals by children is common; use of hand-sanitizer is rarely encouraged and usually only before touching animals not after; food and drink are consumed in areas with animals; and strollers, toys, pacifiers, and children’s cups are all allowed in rooms with animals. This is all against the guidance of the CDC, the AVMA, and the National Association of State Public Health Veterinarians.  

It seems crazy to us that at a time of a national pandemic when we’re all keenly listening to the best health advice on preventing transmission of COVID-19, we wouldn’t also follow government guidance about avoiding exposure to reptile-born salmonella infections. 

But this is also an animal welfare issue.  

Sulcata tortoises (like those we found for sale at Cold Blooded Expos) grow to two and a half feet and can live for more than 70 years—tortoises are considered types of turtles under the law. Caring for them is a lifetime commitment that few people can successfully achieve, let alone comprehend when they are only a few inches small.  

Sulcata Tortoise

Sulcata tortoises sold at a reptile expo in Kansas City

Imagine how many times you move to a new house. Maybe you get married and have kids. Maybe those kids have kids. All the while, this tiny turtle you bought on some idle Sunday during the lockdown continues to grow. They require more and more specialist feed, increasingly larger enclosures, heat lamps, consistent humidity, expensive veterinary care, and both indoor and outdoor space when they get older. 

It’s no surprise, given their specific care requirements and long natural lifespans, that many are dumped outside or abandoned at rescues once the novelty of owning them has worn off. Turtles are also susceptible to many health problems such as respiratory infections, shell rot, and metabolic bone disease.

While estimating mortality in captive reptiles is notoriously problematic, a recent study suggests that around 7.3% of turtles & terrapins die within their first year of acquisition. Other estimates suggest the figure is far higher. Whatever the actual figure, even a 1% mortality rate still means tens of thousands of unnecessary deaths for the nation’s approximately 2 million captive turtles—and that’s just in their first year of captivity. 

We’re happy that FDA finally took action to prevent the sale of tiny turtles at reptile expos. But that’s only a small part of the problem.  

Approximately 10 million reptiles live in people’s homes across the US. The scale of suffering is enormous. Suppose we’re to get serious about the threats posed by zoonotic disease, invasive species, and animal welfare. We need joined-up federal thinking and the under-regulated buying and selling of wild animals has got to end.

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