By Prianka Sharma, Assistant Chief Counsel
On May 2, 2019, Senior Counsel Claudia Rodgers, and Assistant Chief Counsels Bruce Lundegren and Prianka Sharma visited The Hydrant Club, a dog daycare and boarding facility that also offers dog and owner training. Owner Cathy Brooks opened the park portion of the facility in 2013, and the facility was complete in 2015. The Hydrant Club has between four to six employees who work on block schedules depending on the needs of the facility.
The structure of the business is such that potential clients must complete an application process, which includes an informational form, collection of comprehensive health records, a behavioral interview, and a one-time application fee. If the dog passes this process, there are an array of monthly packages depending on the services requested. Because of the quality of care that Brooks offers, some of her customers travel as much as 25 to 45 minutes out of their way to bring their dogs to her facility.
Ms. Brooks spoke about the need for federally mandated animal welfare requirements for dog-care facilities including a dog-to-handler ratio. She suggested 10 to 15 dogs per handler. She also stated that federal guidelines for facilities should be based on the format of services offered at the facility, where the facility is located (urban, suburban, rural as well as region and city), the size of the facility, and the types of screenings offered to customers. For example, the U.S. Department of Agriculture’s proposed rule for animal welfare for dogs has a water feeding requirement. An ample water supply is imperative for these facilities; however, Brooks mentioned that, in some areas, having a continuous flow of water is simply not feasible due to drought and water restrictions. While she always has fresh water available to her dogs, she said that having a continuous stream rather than a measured system, such as one that is activated when the dog steps on a platform, may not be feasible.
Ms. Brooks also spoke about the need for 24-hour staff on-site when a dog is boarded. She mentioned an instance when a warehouse attached to another facility caught on fire and staff were not present at the site. In that instance, luckily building tenants were able to rescue all of the dogs, but she stated that at her facility, if a dog is boarded overnight, staff remain on-site the entire time and have a bedroom in which they sleep in order to monitor the dogs.
One other major regulatory issue that Ms. Brooks spoke about was the U.S. Department of Labor’s Overtime Rule. She stated that the previous final rule as written could put her out of business. Because her employees work in block shifts, they often work over the normal duty hours. If she was required to pay each employee overtime, she would not have the cashflow to do so. Brooks currently determines salary level based on skill, so new employees get paid a lower wage then skilled or veteran employees. She stated that a mandated minimum wage would also severely hurt her business. She said that while she pays each employee a living wage, she also needs the flexibility to pay at the level the employee deserves based on training and experience.
Advocacy staff had a wonderful afternoon visiting with Ms. Brooks and learning about her regulatory concerns, and even playing with some of the dogs!
Advocacy was in Oklahoma, Arizona, and Nevada for Regional Regulatory Reform Roundtables April 29-May 2.
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Prianka Sharma is an Assistant Chief Counsel for Advocacy whose portfolio includes agriculture, energy, and natural resources. Sharma can be reached at Prianka.sharma@sba.gov.
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