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Full Title Name: Detailed Discussion of Fur Animals and Fur Production
Lesley A. Peterson Place of Publication: Michigan State University College of Law Publish Year: 2010 Primary Citation: Animal Legal & Historical Center 1 Country of Origin: United States
This discussion focuses on fur production from both farmed and wild sources. It details US laws that impact fur, both federal and state, including a discussion on state trapping laws. Laws from countries that are major producers of fur products are analyzed as well as those countries that have imposed bans on fur farming or trapping methods.
I. Introduction: Basic Facts about Fur
Throughout the ages, fur pelts from animals have been traded and worn for their warmth and as a fashion statement. Wild fur-bearing animals have been both trapped and hunted in many countries for ages. In Russia, fur served as a form of currency, was used as gifts and as part of a bride's dowry, and became a significant part of trade during the tenth and eleventh centuries. [ 1 ] In the 1530s, the beaver became a main trading item between the American Indians and the colonists, and beaver pelts were regularly shipped to Europe. [ 2 ] By the late 1500s, fur was extremely popular in Europe. In 1608, Samuel de Champlain, a French explorer, created a trading post in Quebec, which became the center of fur trade in America. [ 3 ] In the seventeenth century, Siberia's unification with Russia helped to propel Russia to become the largest fur-supplier, which it remained until the nineteenth century. [ 4 ] Around that time, fur farming started in North America, and was introduced into Europe in the early twentieth century. [ 5 ]
A. Facts about Fur Farming
Today, fur farming comprises about 85% of the fur trade, [ 6 ] while fur from the wild accounts for the rest. [ 7 ] Fur farming is a separate industry from animals that are bred for meat. The meat from some animals bred for their fur, such as rabbits, is sometimes used. However, due to the nature of the intensive confinement systems in which they live, the fur from rabbits bred for their meat is usually not high quality, and thus is often not used. [ 8 ] On fur farms, with the help of strict methods of breeding and diet plans, farmers have been able to create "desirable mutations" and high-quality furs. [ 9 ] The two most commonly bred animals on fur farms are mink and fox. Other fur-farmed animals include fitches (also known as European polecats, which are related to the ferret), finn raccoons, chinchillas, and nutria. Additionally, goat, sheep, fetal and newborn karakul lambs are sometimes bred for their fur. In 2009, 64.73% of the world's mink and 55.6% of the world's fox fur came from European fur farms. [ 10 ] Denmark produced the most farmed mink pelts in the world (30.1%) while China produced 19.3% (the U.S. had the fifth highest amount). [ 11 ] The Netherlands (producing the third most, or 9.7% of all farmed minks), [ 12 ] Finland, and Sweden are also top producers of fur in the EU, [ 13 ] with Finland producing the largest quantity of fox pelts in Europe. [ 14 ] Additionally, fur farming is considered a "key industry" for Poland (producing fourth most, or 7.9% of all farmed minks). [ 15 ] Latvia, Lithuania, and Estonia [ 16 ] are also fur producers as is Kastoria, a Greek town that is one of the main fur manufacturing centers in the world. [ 17 ]
North America also plays a significant role in the fur market. Fur farms in North America were the first to breed black mink, which is the most popular mink pelt. In 2009, black mink pelts accounted for 52% of all pelts produced in the United States. [ 18 ] Fur Commission USA, which is an association representing 400 mink farmers in the U.S., reports that in the U.S., most fur farms are "family businesses, often operated by two or three generations of the same family." [ 19 ] In 2010, the Commission reported having farmer members in Colorado, Connecticut, Idaho, Illinois, Iowa, Indiana, Maine, Maryland, Massachusetts, Michigan, Minnesota, Missouri, Montana, New Hampshire, New Jersey, New York, North Carolina, North Dakota, Ohio, Oklahoma, Oregon, Pennsylvania, South Dakota, Utah, Vermont, Virginia, Washington, West Virginia, and Wisconsin. [ 20 ] The U.S. also hosts mink, fox, chinchilla, rabbit, bobcat, lynx, and finn raccoon farming.
The International Fur Trade Federation ("IFTF"), which is comprised of national associations within 35 countries, [ 21 ] alleges that it promotes strict codes of practice that "meet or exceed established and accepted standards for animal welfare . . . [f]ur farming is well regulated and operates within the highest standards of care." [ 22 ] However, the animal rights organization PETA alleges that animals on fur farms are killed by "anal and vaginal electrocution." [ 23 ] Animal advocacy organization Born Free USA reports that animals confined in cages at fur farms suffer "physical and behavior abnormalities" and also may be killed from being gassed, having their necks broken, or being injected with poisons. [ 24 ]
B. Facts about Wild Fur
The most commonly traded types of wild fur are North American beaver, coyote, ermine, grey fox, red fox, marten, mink, muskrat, nutria, opossum, raccoon, Russian sable, and Chinese weasel. Most wild fur is obtained from Canada, Russia, and the U.S. [ 25 ] Trappers generally use "baited and concealed traps" during the time of year when the desired animal has the highest quality coat (this is usually at the start of winter). [ 26 ] Wild fur is mainly traded by hunters and trappers in U.S., Canadian, European, and Russian auction houses, where pelts are bought and subsequently processed into clothing. [ 27 ]
The IFTF states that the majority of wild fur is obtained from wildlife management programs, which are necessary for "maintenance of biodiversity and healthy eco-systems, population and disease control and the protection of public lands and private property." [ 28 ] Additionally, the Association of Fish and Wildlife Agencies alleges that trapping is beneficial to conservation efforts. [ 29 ] However, animal welfare organizations say that trapping has many harmful effects on wildlife. First, they argue that trapping can cause species to become endangered once popularity of pelts rise and those species become more prone to extinction. Second, they allege that trapping can increase the spread of disease, as healthy animals are more likely to be lured into traps than weak animals, thus reducing the "genetic strength" of the animals. Third, they argue that trapping can contribute to the overpopulation of wildlife, as it can cause some species to reproduce more quickly than normal, which can upset the "delicate and complex balances that exist in nature." [ 30 ] PETA reports that animals in the wild are drowned, trapped, or beaten to death. [ 31 ] Born Free USA reports that animals caught in traps may remain there "for several days before starving or dying from exposure." [ 32 ] Snares can slowly strangle animals to death, and animals whose limbs are caught in leg-hold traps may chew off their paws to escape and then subsequently die from the injury. Additionally, traps can be dangerous because they can kill or injure any animal that comes into contact with them. Animals that are trapped by mistake are deemed "trash animals" because they do not have any economic value to the trappers, and according to Global Action Network, an animal and environmental protection organization, "[t]rappers themselves report that three to ten 'nontarget' animals . . . are caught in the trap for each intended victim." [ 33 ]
C. Other parts of the Fur Trade
Some aquatic animals such as harp seals are hunted for their pelts. Canada and Greenland's commercial seal hunts make up 50% of all seals hunted, [ 34 ] while Namibia hosts the only hunt south of the equator. [ 35 ] Baby harp seals in Canada cannot be legally hunted until they begin to shed their white coats of fur. However, this happens at a very young age. In 2006, the Humane Society International, an animal protection organization, reported that "97 percent of the seals killed in the commercial seal hunt over the past three years have been younger than 3 months, and most were younger than 1 month old." [ 36 ] Polar bears are hunted for their fur and meat by indigenous communities in the Arctic, but they are also used as trophy pelts. Additionally, dogs and cats are part of the fur trade. Global Action Network alleges that 2 million dogs and cats are killed in primarily China and South East Asia every year for the fur trade, and that dogs are traditionally killed by being hung from their paws and are bled to death from an artery cut in their thigh, while cats are often "strangled with wire nooses." [ 37 ]
II. Animal Rights Organizations and the Future of Fur
In 1988, the World Society for the Protection of Animals, an alliance of animal welfare organizations, launched its "No Fur" Campaign, which was subsequently adopted by over fifty other organizations. [ 38 ] In the same year, PETA launched an undercover investigation of a Montana beaver farm, which led to its closure, and started to use donated furs in demonstrations and educational displays. [ 39 ] Around the same time, PETA also made headlines when one of its members put a dead raccoon onto Editor-in-chief of fashion magazine Vogue Anna Wintour's plate at the Four Seasons, and hit fashion designer Oscar de la Renta in the face with a tofu cream pie. Anti-fur campaigns successfully created a negative image of fur, and activist protests led to a decline of fur used in fashion during the 1980s; however, fur has been making a comeback since the 1990s, and in March 2010, "[f]or the first time in more than two decades, more [New York fashion] designers are using fur than not." [ 40 ]
III. Production and Fur Sales
In 2008, about 56 million pelts of fur were produced worldwide. [ 41 ] Fur trim is a large market and the number of animals killed for it is predicted to exceed those killed for clothing made entirely by fur. [ 42 ] The U.S. is a "major exporter of pelts," but its fur apparel production has decreased significantly, thus making it a net importer. [ 43 ] The U.S. is able to acquire some of the highest prices for its mink pelts, but now it has less than 300 farms, mainly in Wisconsin. [ 44 ] In 2008, the U.S. imported fur mainly from China (44.4%), Canada (16.4%) and Italy (13.9%), and exported fur to China (21.5%), Canada (13.4%) and Italy (8.2%). [ 45 ] In March 2010, the IFTF reported that global fur sales remained stable during the 2008-2009 global recession, and while fur sales in Europe have remained around $4 billion for 2007-2009, Asian markets have experienced increased demand, for a total global fur sale figure "at just over $13 billion." [ 46 ] This number is stable from the past few years, but lower than the global $15.02 billion in 2006-2007. [ 47 ]
Russia and China are increasing their production of and market for fur, and China's cheap labor and lack of regulatory oversight have attracted more business. It is difficult to get a true sense of China's market share, since most of its fur farms are family-owned businesses, the pelts are often "sold on the free market" (as opposed to auctions), and the country lacks official statistics about its fur production, yet at the same time the U.S. Department of Agriculture ("USDA") believes that China is the world's leading fur processor. [ 48 ]
A. Real Fur Sales Versus Faux Fur Sales
For people who like the look of fur, but do not want to kill animals, faux fur can be an attractive alternative. Faux fur is usually made of acrylic fibers that can be dyed to look like animal fur. There has been recent controversy over real fur which is unlabeled or mislabeled as faux fur. Due to this fact, HSUS has created a guide to help people to determine whether a product is made of real or faux fur:
1. Check the base of the fur for skin or fabric. Push apart the fur and look at the material at the base of the hairs. If the base material is not visible or unclear, and you own the garment, break the stitching and look at the non-hair side of the fur base, being sure to peel away all the layers of the lining.
ANIMAL FUR: The surest sign of animal fur is leather/skin (usually white or tan, but possibly the color of the fur if it has been dyed).
FAKE FUR: The surest sign of fake fur is seeing the threadwork backing from which the "hairs" emerge.
2. Check the tips of the hairs for tapering. Both animal fur and fake fur come in many different colors and lengths. However, if animal fur has not been sheared or cut to a uniform length or had the guard hairs plucked out, you may be able to examine the tips of the longest hairs and see that they taper into a fine point—like a cat's whisker or sewing needle. Good lighting and a magnifying glass are helpful, as is holding the hairs up against a white surface.
ANIMAL FUR: Animal hairs—especially the thicker guard hairs . . .—can often be seen tapering to a point. NOTE: This test can give a false negative for animal fur if the hairs have been sheared or plucked.
FAKE FUR: [There is a] straight across cut [in] fake fur "hair." NOTE: Tapering has not been seen on any fake fur samples to date, but such a process may exist, or come into existence.
3. The Burn Test (only if you own the coat). Animal hair smells like human hair when burned; fake fur made from acrylic or polyester—the two most commonly used synthetics—does not. Carefully remove just a few hairs and then, holding them with tweezers above a dish or other non-flammable surface, ignite them with a cigarette lighter. Make sure to burn them away from the original garment and anything else flammable. Never conduct the burn test on hairs still attached to the jacket. The burn test should only be conducted by adults . [ 49 ]
There is controversy over whether faux fur or real fur is more "environmentally friendly." A 2004 British newspaper article quotes Executive Director of Fur Commission USA Teresa Platt as saying that "'[f]aux fur jackets do not degrade for at least 600 years and may take thousands of years,'" and Ruth Rosselson from In Touch magazine as saying that polyester and nylon, which are used to make fake fur, are synthetic materials that are "'responsible for large-scale factory pollution of our waterways, rivers, canals and even the sea.'" [ 50 ] However, PETA alleges that it takes twenty times more energy to produce a real fur coat from farm-raised animals than it does to create a faux fur coat, that fur is not biodegradable because it contains chemical treatments to prevent it from rotting, and that "mink factory farms generate tens of thousands of tons of manure annually . . . [and can produce] nearly 1,000 tons of phosphorus, which wreaks havoc on water ecosystems." [ 51 ]
IV. US Federal Regulation of the Fur Industry
There is very little federal law regarding treatment of fur animals. While U.S. Congress has created the Animal Welfare Act to ensure humane treatment of animals, it specifically exempts "animals . . . used or intended for use as food or fiber." [ 52 ] Similarly, the Humane Methods of Slaughter Act , which requires livestock to be slaughtered humanely to prevent "needless suffering," does not extend protection to fur animals. [ 53 ] An examination of all the federal laws that reach fur animals is instructive.
A. The Lacey Act [ 54 ]
The Lacey Act, 16 U.S.C. §§ 3371-3378 , prohibits wildlife trade in animals that have been illegally taken, possessed, transported or sold. However, this law cannot always prevent poaching because "state laws vary widely. If a poacher kills a bear in a state that prohibits trade in bear parts, the poacher can avoid prosecution by transporting the body to a state that does permit it. Although such transporting is illegal, a prosecutor must prove that the bear was illegally killed in a state that prohibits commerce in bear parts, which can be very difficult to do." [ 55 ] The Lacey Act only applies to wild fur and not to fur obtained from fur farms.
B. The Fur Seal Act [ 56 ]
The Fur Seal Act, 16 U.S.C. §§ 1151-1187 , makes it illegal to take North Pacific fur seals anywhere in the U.S., and mandates the Secretary of Commerce to regulate the fur seal breeding colonies on the Pribilof Islands, (part of Alaska), to ensure that activities on the Islands do not deter the conservation of the North Pacific fur seals. However, Indians, Aleuts and Eskimos who live on the North Pacific coast are allowed to take fur skins if they are taken for subsistence. Additionally, the Secretary of Commerce is allowed to take North Pacific fur seals or parts of these seals if deemed for education, science, or for an exhibition. The Fur Seal Act only applies to wild fur and not to fur obtained from fur farms.
C. The Marine Mammal Protection Act [ 57 ]
The Marine Mammal Protection Act, ("MMPA") 16 U.S.C. §§ 1361 - 1421h , was created to protect marine mammals that are in danger of extinction or depletion because of human activities; the Act applies to mammals that primarily live in the water and to all parts of the mammal, including its fur. The MMPA prohibits the taking of marine mammals, except in the case of permits issued by the Secretary of Interior for "scientific research, public display, photography for educational or commercial purposes, or enhancing the survival or recovery of a species or stock or for importation of polar bear parts (other than internal organs) taken in sports hunts in Canada," [ 58 ] as well as for commercial fishing operations (when marine mammals are taken incidentally). The Secretary can also waive the requirements of the law for specific circumstances. The MMPA only applies to wild fur, and not to fur obtained from fur farms.
D. Polar Bear Bills Pending in Congress
Currently, there are three bills in Congress addressing the taking of polar bears from sports hunts in Canada. H.R. 1054, introduced by Representative Young from Alaska, would have the Secretary issue a permit allowing polar bear parts (besides internal organs) to be imported from Canadian sports hunts that occurred before the polar bear was determined to be "threatened" under the Endangered Species Act. [ 59 ] The bill was referred to the Subcommittee on Insular Affairs, Oceans and Wildlife, subcommittee hearings were held in 2009, and no further action was taken. Sen. 1395, introduced in 2009 by Senator Crapo from Idaho, contains very similar language. [ 60 ] It was referred to the Committee on Commerce, Science, and Transportation, and no further action was taken. H.R. 1055, also introduced by Representative Young from Alaska, would allow polar bear parts to be imported from all Canadian sports hunts [61] (thus, it is broader than H.R. 1054). The bill was also referred to the Subcommittee on Insular Affairs, Oceans and Wildlife in 2009, and no further action was taken.
E. Fur Labeling [ 62 ]
The Fur Products Labeling Act, 15 U.S.C. § 69, declares that fur products will be considered "misbranded" if "falsely or deceptively labeled" or identified, and/or if the product does not contain a label that legibly shows the name(s) of the animals from which the fur was taken, the name or other identification of the person(s) who manufactured the fur, and the country of origin of the fur. The label must also state, if true, that the fur product contains used or artificially colored fur, and/or if it is "composed in whole or in substantial part of paws, tails, bellies, or waste fur." However, the law defines "fur product" as an article of clothing that is made in whole or in part by fur, but states that the Commission can exempt articles because of the small quantity of fur they contain. The Federal Trade Commission has deemed "relatively small quantity or value" to equal $150, which means "multiple animal pelts [can exist] on a garment without a label." [ 63 ]
HSUS has been advocating for an amendment to the law closing this loophole, after its investigators found "dozens" of designers selling unlabeled jackets that contained animal fur, and mislabeled jackets that said they contained faux fur, but really contained animal fur. [ 64 ] In May 2009, Representative Moran introduced H.R. 2480, the Truth in Fur Labeling Act, which would amend the Fur Products Labeling Act by eliminating the exemption for fur products under $150 that allows them to be unlabeled. [ 65 ] This act would not apply to fur from hunting or trapping which is sold by the hunter or trapper "in a face to face transaction," where the money made is not the person's primary source of income. [ 66 ] On July 28, 2010, the bill passed the House, and was referred to the Senate Committee on Commerce, Science, and Transportation on August 5, 2010. Supporters of the bill think that consumers will be better protected by this legislation because they will be able to make "informed purchasing decisions," and they allege that companies will no longer be able to take advantage of the $150 loophole (since the loophole allows cat and dog fur to "slip into the United States [undetected] despite the ban.") [ 67 ] Detractors of the bill compare fur farming killing methods to those used by animal shelters, they say that cat and dog fur are not traded in North America, and that all fur meets appropriate labeling requirements and is farmed legally. [ 68 ]
F. Dog and Cat Fur Protection Act [ 69 ]
The Dog and Cat Fur Protection Act, 19 U.S.C. § 1308 , prohibits the import, export, and sale of dog and cat fur products in the U.S. The law requires that the Secretary of Treasury submit a report to Congress every year on the government's enforcement efforts and its ability to do so. The report is to include any findings that a particular government has supported the dog or cat fur trade.
G. Endangered Species [ 70 ]
The Endangered Species Act, 16 U.S.C. §§ 1531-1541 , works to develop conservation programs to protect endangered and threatened species, acknowledges the U.S.' commitment to conserving, as much as practical, wildlife under the Convention on International Trade in Endangered Species of Wild Fauna and Flora ("CITES"), and encourages states to create conservation programs (with federal financial assistance) that meet national and international conservation standards. A species is deemed "endangered" if it is "in danger of extinction throughout all or a significant portion of its range" or "threatened" if it is "likely to become an endangered species within the foreseeable future throughout all or a significant portion of its range." Fur-bearing animals on the list of endangered species include some types of bears, beavers, cheetahs, leopards, monkeys, rabbits, tigers, yaks, and zebras. Although the Endangered Species Act protects animals on its list, it allows people to own endangered species, and may even allow them to hunt those animals. [ 71 ] Thus, some species that are listed may in fact be hunted for their fur.
V. US State Regulation of the Fur Industry
It is often times unclear under what classification of laws, fur animals belong. Trapping and hunting laws are generally under State Wildlife, Fish & Game, or Environmental Conservation Codes, labeling laws are under Trade Practice Codes and cat and dog fur laws are under anything from the Criminal Code to the Agriculture Code.
Fur Commission USA reports that state departments of agriculture regulate fur farms. [ 72 ] However, specific laws regarding such regulation are scarce, and are mainly confined to defining fur farming as an "agricultural pursuit" and designating the animals as either domestic animals or livestock. For example, Wisconsin, which has the most fur farms in the U.S., has a law stating that fur farming is an "agricultural pursuit, and all such animals so raised in captivity shall be considered domestic animals," and thus subject to the laws for domestic animals. [ 73 ] Michigan has a similar law, which declares "silver, silver-black, black, and cross foxes" on fur farms to be domestic animals, as distinguishable from livestock. [ 74 ] In California, animals that are fur farmed are considered to be domestic animals, yet the statute differentiates between fur animals and "dogs and cats or other pets," and states that the animals will be considered domestic animals for the purposes of laws relating to farming and animal husbandry. [ 75 ] In Idaho, fur farming is again defined as an "agricultural pursuit," but here, the animals are considered to be livestock. [ 76 ] Idaho has some of the most extensive laws, including one giving its Animal Industries Division the right to inspect fur farms at any time. [ 77 ] Minnesota requires a fur farmer to register with the state to provide information about the number of pelts he or she sells. [ 78 ] In Montana, a farmer must obtain a fur farm license in order to operate a fur farm, but the law specifically excludes fox and mink fur farms. [ 79 ]
Born Free USA published a 2009 report which alleged that many states allow fur farms to be unregulated:
No states reported having comprehensive laws specific to the regulation of fur farms and no states monitor the care and treatment of animals housed and killed on fur farms. As a result, fur farms are virtually unregulated in every state where fur farming exists.
In response to formal requests for information from Born Free USA, the vast majority of Departments of Agriculture in fur-farming states reported having no specific responsibilities or regulatory authority over fur farming in the state. Of those states reporting that their Department of Agriculture has statutory authority to regulate fur farms (Idaho, Massachusetts, Michigan, Minnesota, New York, South Dakota), none had exercised this authority by issuing regulations. [ 80 ]
A. Trapping Laws
Born Free USA alleges that trapping laws are state-regulated and are often poorly enforced. [ 81 ] Trapping laws typically specify the season during which species can be taken. They also set up licensing procedures, with administrative regulations detailing the types of traps that hunters can use. Many states do not restrict the type of traps, how many animals can be trapped, and the regularity in which trappers must check their traps. However, a significant amount of states have banned leg-hold traps, which is a trap designed to hold an animal's limb so the rest of its fur is not damaged. Colorado, [ 82 ] New Jersey, [ 83 ] Washington, [ 84 ] and Massachusetts [ 85 ] are such states. In Arizona, leg-hold and instant kill traps are banned on public lands. [ 86 ] In Rhode Island, leg-hold traps are banned, but a person can apply for a special permit to use a leg-hold trap on his or her property when he or she has an "animal nuisance" that "cannot be reasonably abated except by the use of the trap." [ 87 ] In Maryland, leg-hold traps cannot be within 150 yards of a "permanent human residence." [ 88 ] In other states, such as California, [ 89 ] New York, [ 90 ] and Iowa [ 91 ] leg-hold traps of a certain diameter are banned. Wyoming permits leg-hold traps, but requires that the trapper check them at least once every 72 hours. [ 92 ]
B. Fur Farming and Trapping under Anti-Cruelty Laws
Lines are also somewhat vague in terms of animal cruelty laws and how they relate to wild fur animals and those raised on fur farms. While state anti-cruelty laws generally exclude legal trapping or agricultural pursuits, sometimes this distinction is not so clear. In Florida, a man was convicted of felony cruelty to animals after he shot an opossum with a BB gun that he had found in his garage, shooting it so many times and injuring it so severely that it had to be euthanized. [ 93 ] Even though the opossum was a "fur-bearing animal," which meant that a licensed hunter could "take" it, the relevant cruelty law "applies to even the unintended consequence of a lawful act." [ 94 ] In fact, the court observed that this was a "blurred line between the lawful hunting of an animal and the commission of a criminal act." [ 95 ]
Alabama's anti-cruelty law applies to the cruel mistreatment of any animal. [ 96 ] However, most other anti-cruelty laws exempt animals hunted or raised on fur farms. Arizona's anti-cruelty statute does not "prohibit or restrict" any activities that are deemed to be regulated by Arizona's Game and Fish Department or its Department of Agriculture. [ 97 ] Similarly, Idaho forbids a person from treating any animal cruelly, but further states that the law is not meant to interfere with "[n]ormal or accepted practices of animal identification and animal husbandry" or "[a]ny other . . . practices or procedures normally or commonly considered acceptable." [ 98 ] Connecticut [ 99 ] and Texas [ 100 ] have similar laws, but exempt hunting and "generally accepted" agricultural activities. While state cruelty laws do not generally apply to either trapping or fur farming activities, some states have enacted companion laws that require humane euthanasia for fur-bearing animals. For example, New York specifically prohibits electrocution of fur-bearing animals, [ 101 ] while California prohibits using carbon monoxide gas or an injection directly into the heart muscles or ventricles of a euthanasia agent to kill a conscious animal, unless the animal is "heavily sedated or anesthetized in a humane manner." [ 102 ]
C. Labeling Laws
Five states have labeling laws that are stricter than the federal fur labeling law. Delaware [ 103 ] and New Jersey [ 104 ] require garments containing real animal fur to contain labeling stating so. Wisconsin has a similar law, but the labeling requirement does not apply to garments that are sold for less than $50. [ 105 ] In Massachusetts [ 106 ] and New York, [ 107 ] both real and faux furs must be labeled as such. In California, A.B.1656 passed the Assembly and Senate in August 2010, which would require labels on all clothing that contained animal fur, but the bill still needs to be approved by Governor Schwarzenegger, who has not yet disclosed his position. [ 108 ]
D. Dog and Cat Fur
A handful of states have laws concerning dog and cat fur. Alabama, [ 109 ] Delaware, [ 110 ] New Jersey, [ 111 ] New York, [ 112 ] Pennsylvania, [ 113 ] and Virginia [ 114 ] prohibit trade in domestic dog or cat fur. Virginia also prohibits killing a dog or cat for its fur, [ 115 ] while Florida prohibits killing a dog or cat with the "sole" intention of either selling or giving away the pelt of the animal. [ 116 ] In Oregon, a person cannot buy or sell dog or cat fur that is obtained from "a process that kills or maims the cat or dog." [ 117 ]
Although fur farming makes up 85% of the total fur production, there are very few on-point laws regulating it. While there are a plethora of laws regarding trapping licenses, and a few laws banning certain types of traps, states do not have laws regulating fur farms, outside of the need to obtain licenses and the definition of the fur animals. Additionally, only a handful of states have fur labeling laws and prohibit dog and cat fur trade, although there are federal on-point laws for each of these subjects.
VI. Commerce in Illegal Fur
Even though the majority of fur obtained worldwide is from fur farms, an illegal wildlife trade still flourishes. This trade, (including the illegal fur trade) is annually worth between $5-$20 billion, with the Congressional Research Service reporting that "'the illegal wildlife trade is among the most lucrative illicit economies in the world behind illegal drugs and possibly human trafficking and arms trafficking.'" [ 118 ] Much of the illegal fur is obtained from endangered animals that are against the law to hunt.
A. Tiger and Leopard Fur Trade
Tigers and leopards are both considered endangered species, and thus their international commercial trade is prohibited under CITES . According to a report conducted by the Environmental Investigation Agency ("EIA") and the Wildlife Protection Society of India ("WPSI") in 2006, "[t]he illegal trade in poached skins between India, Nepal and China is the most significant immediate threat to the continued existence of the tiger in the wild." [ 119 ] Although India and China are signatories to CITES, which has given recommendations to help stop illegal trade, the countries have not implemented the recommendations and leopard and tiger skins have been subject to trafficking by international organized crime networks. Poachers can be paid $1,500 in India and $16,000 in China for one tiger skin; fines in India and Nepal are only $440 and $1,420, respectively. [ 120 ]
Tiger and leopard skins originally were used mostly for Tibetan chupas, which are worn at festivals and weddings. However, now there is an increasing demand for the skins to be used as decorations in the home and expensive gifts. Tigers are caught in traps and then shot, or clubbed or speared through the mouth so that the skin remains intact. Professional tiger and leopard poachers from traditional hunting communities have become famous for using steel jaw traps and guns, and also for poisoning and electrocuting the animals. [ 121 ]
In 1993, China illegalized imports, exports, transport, and purchase of tiger products. [ 122 ] However, at a 2007 CITES meeting, China said that the trade ban had proven ineffective because wild tiger populations were still decreasing, and the ban had "seriously impacted . . . the Chinese traditional culture." [ 123 ] China argued that it should be legal to farm tigers for their bones and skin, and the country has allowed tiger breeding farms. In 2007, China reported having 5,000 tigers on its farms. [ 124 ]
At the March 2010 CITES meeting, all member nations agreed to increase law enforcement and cooperation between countries where tigers exist, as well as to "create a tiger trade database that could be analyzed to develop anti-poaching strategies." [ 125 ] The South Asia Experts Group on Illegal Wildlife Trade will work to respond to poaching and trafficking issues. Additionally, a potential resolution was introduced at the 2010 CITES meeting to create further limitations on the domestic trade of tigers, but it did not pass, and regulations of tiger farms were not modified. However, HSUS reports that there was a "renewed call" for countries such as China who allow tigers to be bred for commercial trade, to end such activity. [ 126 ]
B. Polar Bear and Bobcat Fur Trade
At the 2010 CITES meeting, the U.S. proposed to change the polar bear's listing status on the CITES appendices; this was defeated by the European Union's ("EU") opposition to such a change. [ 127 ] Such a ban would have moved the polar bear from inclusion on CITES' Appendix II, where regulated international commercial trade is permitted, to inclusion on Appendix I as an "endangered species," where no international commercial trade is allowed.
The U.S. also attempted to remove the bobcat from Appendix II, where its skins can only be exported if the exporting country determines that the export will not hurt the species' chances of survival. However, this proposal was defeated.
VII. Other International Trade Issues
International countries have a wide range of laws pertaining to fur-bearing animals. For an example, China has virtually no regulations protecting such animals. On the other side of the spectrum, the EU has a host of regulations. Animals kept for farming purposes, including fur-bearing animals, are protected under EU Council Directive 98/58, which mandates, (through the enactment of laws in its member states), that animal owners "ensure the welfare of animals under their care and [] ensure that those animals are not caused any unnecessary pain, suffering or injury." [ 128 ] Additionally, EU Council Directive 93/119 protects animals at the time of slaughter or killing, and includes specific methods in which an animal produced for its fur can be killed. [ 129 ]
A. Fur Farming Limitations
Austria and the United Kingdom have banned fur farming, and Croatia began a ten-year phase-out in 2007. [ 130 ] The Netherlands has banned fox and chinchilla farming, and strict regulations regarding farming and imports have effectively banned mink farms in New Zealand, fox farms in Sweden, and all fur farms in Switzerland. [ 131 ]
B. Leg-Hold Trap Bans
Over 60 countries have banned the leg-hold trap. [ 132 ] The EU passed Regulation 3254/91, which prohibits leg-hold traps, as well as fur imports from other countries that were obtained from leg-hold traps or other traps that do not meet "international humane trapping standards." [ 133 ] The EU reached and ratified an agreement regarding international humane trapping standards with Russia and Canada, and also reached a similar agreement with the U.S. The Commission also proposed a Directive in 2004 which would introduce humane trapping standards for specific species. The European Economic and Social Committee reviewed the proposed Directive, and found that the Agreement's use of the word "humane" to define the type of trapping allowed, was "controversial, given that these standards are based on the acceptance of high level of suffering for the trapped animals," and therefore recommended that the word "humane" be eliminated from the text, that the drowning trap should be prohibited and a "transparent system" of licensing trappers should be implemented, in order to ensure that appropriate welfare standards are upheld. [ 134 ] The proposed Directive has not yet been adopted.
C. Imported Seal Products Ban
In 1983, the EU banned the import of seal pup products made from whitecoat harp seal pups seals and of hooded seal pups (the Directive does not apply to products from Inuit traditional hunting). [ 135 ] The U.S., Belgium, Netherlands, Mexico, Slovenia, and Croatia have prohibited the seal product trade. [ 136 ] In May 2009, the EU set forth a regulation which banned seal product trade within its countries. Canada and Norway (who is not a member of the EU) have alleged that the ban is a violation of WTO trading obligations. [ 137 ] Supporters of the ban say that seal slaughter is cruel and inhumane, while those in opposition disagree, and further say that a ban will destroy the hunters' jobs. [ 138 ] The ban started on August 20, 2010, although some hunters are currently exempt, due to a pending lawsuit. [ 139 ]
D. Fur Products Ban
On September 2, 2010, Israel is planning to vote on a bill which would "prohibit the production, processing, import, export, and sale of fur from all animal species not already part of the meat industry." [ 140 ] The bill provides a "cultural" exception so that Hasidim Jews can still obtain their fur-covered hats (or shtreimels). [ 141 ] The IFTF believes that there is no justification for the bill, as it says that the fur trade is mindful of animal welfare and conservation. [ 142 ]
E. Cat and Dog Fur Trade and Labeling Laws
The EU banned the import, export, and placing into the market of dog and cat fur in 2007. [ 143 ] The U.S. [ 144 ] and Australia [ 145 ] also have such bans. The IFTF supports these bans. [ 146 ]
In terms of labeling, the IFTF reports that the U.S. Canada, Russia, the Ukraine, China, and parts of the EU have fur labeling requirements. [ 147 ]
F. CITES
CITES is an international agreement that works to create a sustainable wildlife trade. [ 148 ] There are currently 175 parties to the Convention, including China, India, the U.S., the Russian Federation, and Canada. [ 149 ] The EU is not a member, but has implemented the agreement's provisions in its community law. [ 150 ] While CITES parties are legally bound to the Convention's terms, each party must adopt domestic legislation in order to implement CITES in its particular country. CITES looks at the international trade of certain species and protects them in three different ways, depending under which Appendix a species falls. Appendix I contains species that are threatened with extinction. CITES permits trade of those species only in rare situations. Appendix II contains species that do not necessarily face extinction, but must have controlled trading circumstances in order to protect them. Appendix III contains species that are protected by at least one country that has asked CITES to help it control the trade of that species. Parties are able to submit proposals at regular Conference of the Parties meetings to try to amend either Appendix I or II. All import and export activity of any species falling within an Appendix must be subjected to the Convention's licensing system; for example, a species under Appendix I will only be issued an import permit if it is not going to be used mainly for commercial purposes and if the import's purpose will not hurt the species' survival. The fur trade is directly affected by CITES because, depending on a species' listing under Appendix I or II, it is either prohibited from commercial trade, or its trade is monitored.
The fur industry is predominantly supported by fur farming. It seems, due to the ease in regulating an animal's reproduction and coat quality through farming that this method will continue to predominate over hunting. China's increasing market share and its lack of regulatory oversight (resulting in alleged cruel slaughter methods and the use of dog and cat fur), have the potential to change the fur industry landscape. Some U.S. states have laws concerning the proper labeling of fur and the prohibition of dog and cat fur. The U.S. also has on-point federal laws for both issues, and the EU and Australia have similar laws regarding the sale of dog and cat fur. There are also international movements to protect endangered animals from the illegal fur trade. The U.S. supports such a movement through its role in CITES; however, its pending legislation at home regulating the taking of certain animals who are at least deemed "threatened," (such as polar bears), seems largely dependent upon the political party in office. Additionally, sophisticated fur industry trade organizations have denounced unregulated and illegal fur trades. These associations, when faced with the possibility of losing market share to China, could put pressure on China to devise regulations (and to thus "level the playing field").
At the same time, the U.S. is lagging behind the rest of the world in terms of regulations regarding the treatment of animals that are farmed or hunted for their fur. Many countries have strict rules regulating or banning fur farming. However, the fact that China is the major player in the industry, and also has an increasing demand for fur, begs the question of whether these attempts by other countries are futile, as the fur production is merely "outsourced" to Asia. While the U.S. used to be a big fur producer, this is no longer the case, thus its lack of regulations could soon become moot.
One country, Israel, has introduced a possible ban on the production and sale of fur within its national confines. If this becomes law, its potential to influence other countries – especially ones who have already banned certain fur products – is significant. At the same time, designers have renewed their use of fur on the runway, thus showing fur's continuing prominence in fashion. In all, the future of the fur industry and its prominence in society is very uncertain. Whether China's increasing production or laws calling for more regulation will win, remains to be seen.
[1] Russian Furs: History , Int ' l Fur Auction, http://www.sojuzpushnina.ru/en/s/55/ (last visited Sept. 5 , 2010).
[2] Welcome to the FUR INDUSTRY Story , Quality Furs, http://www.qualityfurs.com/modules.php?name=Fur_History (last visited Sept. 5, 2010).
[3] The Fur Trade, Powell County Museum & Arts Found . , http://www.pcmaf.org/fur_trade.htm (last visited Sept. 5 , 2010).
[4] Russian Furs: History , supra note 1.
[5] Farmed Fur, Int ' l Fur Trade Fed ' n, http://www.iftf.com/#/farmed-fur/ (last visited Sept. 5 , 2010).
[6] Id.
[7] Wild Fur, Int ' l Fur Trade Fed . , http://www.iftf.com/#/wild-fur/ (last visited Sept. 5, 2010).
[8] Born Free USA, Consumers for a Fur Free Society , Beyond the Myths and Propaganda: Facing the Facts 4 http://www.bornfreeusa.org/downloads/pdf/What_Wrong_with_Fur.pdf [hereinafter Consumers for a Fur Free ].
[9] Fur , Encyclopedia Britannica, http://www.britannica.com/EBchecked/topic/222466/fur?anchor=ref114465 (last visited Sept. 5, 2010).
[10] Fact Sheet, European Fur Breeders' Assoc . , http://www.efba-eu.com/fact_sheet.html (last visited Sept. 5, 2010).
[11] World Mink Production , Fur Comm ' n USA, http://www.furcommission.com/farming/pelts.htm (last visited Sept. 5 , 2010).
[13] U.S. Int ' l Trade Comm ' n, Industry & Trade Summary: Furskins 11 ( January 2004 ) , available at http://www.usitc.gov/publications/332/pub3666.pdf .
[14] Fact Sheet, supra note 10 .
[15] World Mink Production , supra note 11 .
[17] Lauren Etter, Slowing Economy Pelts the Global Fur Business, The Wall Street Journal , Feb. 12, 2009, http://online.wsj.com/article/NA_WSJ_PUB:SB123439872449675207.html .
[18] Fur Farming in North America , Fur Commission USA, http://www.furcommission.com/farming/index.html#Anchor-Fur-Producing-49575 (last visited Sept. 5 , 2010).
[21] Who We Are , Int ' l Fur Trade Fed . , http://www.iftf.com/#/who-we-are/ (last visited Sept. 5 , 2010).
[22] Welfare , Int ' l Fur Trade Fed . , http://www.iftf.com/#/welfare/ (last visited Sept. 5 , 2010).
[23] Fur Is Dead , http://www.furisdead.com/ (last visited Sept. 5 , 2010).
[24] Consumers for a Fur Free Society , supra note 8, at 12.
[25] Wild Fur, supra note 7 .
[26] Fur , supra note 9.
[27] Int ' l Fur Trade Fed . , Wild Fur Book 20 http://www.iftf.com/wildfurbook/ (last visited Sept. 5 , 2010) .
[28] Int ' l Fur Trade Fed . , Socio-Economic Impact of International Fur Farming 1 ( 2006 ) , http://www.fur.ca/files/IFTF_Socio_Economic_Impact.pdf .
[29] Assoc . of Fish & Wildlife Agencies, Fact Sheet: Furbearer Management 1, http://www.fishwildlife.org/pressroom/factsheets/_Furbearer_factsheet.pdf .
[30] Fur Trade Factsheets: Trapping and the Environment , Global Action Network, http://www.gan.ca/campaigns/fur+trade/factsheets/trapping+and+the+environment.en.html .
[31] Fur I s D ead, supra note 23 .
[32] Born Free USA, Trapping and Fur Trade: Cruel and Unnecessary , http://www.bornfreeusa.org/a10_trapping.php (last visited Sept. 5 , 2010).
[33] Fur Trade , Global Action Network, http://www.gan.ca/campaigns/fur+trade/factsheets/trapping+and+the+environment.en.html
[34] Inuit Sue to Overturn EU Seal Product Ban Law, EU Bus ., Jan. 14, 2010, http://www.eubusiness.com/news-eu/greenland-canada.29x .
[35] Condemnation of Namibia's Commercial Seal Hunt as EU Prepares for Seal Ban , Int ' l Fund for Animal Welfare, ( July 15, 2010 ) , http://www.ifaw.org/ifaw_european_union/media_center/press_releases/7_15_2010_63188.php .
[36] Myths and Facts: The Truth about Canada's Commercial Seal Hunt , Humane Soc ' y Int ' l, ( Feb. 25, 2006 ) , http://www.hsi.org/issues/protect_seals/research/seal_myths_and_facts.html .
[37] Fur Trade: Cat and Dog Fur , Global Action Network, http://www.gan.ca/campaigns/fur+trade/cat+and+dog+fur.en.html .
[38] History, World Soc ' y for the Prot . of Animals, http://www.wspa-usa.org/pages/13_history.cfm (last visited Sept. 5 , 2010).
[39] History of Our Fur Campaign, Fur I s D ead, http://www.furisdead.com/history.asp (last visited Sept. 5 , 2010).
[40] Eric Wilson, Fashion Feels Fur's Warm Embrace , N.Y. Times, Mar. 10, 2010, http://www.nytimes.com/2010/03/11/fashion/11FUR.html?scp=1&sq=anti%20fur%20campaign&st=cse .
[41] Farmed Fur, supra note 5 .
[42] Consumers for a Fur Free Society , supra note 8, at 7.
[43] US Mink: State of the Industry – 2009 , Fur Comm ' n USA , ( June 23, 2009 ) , http://www.furcommission.com/resource/perspect999co.htm [hereinafter US Mink: State of the Industry – 2009 ].
[44] E tter, supra note 17.
[45] US Mink: State of the Industry – 2009 , supra note 43 .
[46] Press Release, Int ' l Fur Trade Fed . , Global Fur Sales Remain Stable During 2008/2009 Recession (March 16, 2010), available at http://www.furcommission.com/news/newsF11y.htm .
[48] USDA Foreign Agric. Serv. G AIN Report, People's Republic of China, Fur Animals and Products 2 ( May 25, 2010) http://gain.fas.usda.gov/Recent%20GAIN%20Publications/Fur%20Animals%20and%20Products_Beijing_China%20-%20Peoples%20Republic%20of_5-25-2010.pdf .
[49] Humane Soc'y of the U . S. , Field Guide to Telling Animal Fur from Fake Fur , http://www.hsus.org/web-files/PDF/fur/field-guide-on-real-vs-fake-fur-final.pdf .
[50] Sue Reid, Should You Be Faking It? Are You Wearing Fake Fur and Feeling Just a Tiny Bit Smug? Daily Mail, Nov. 22, 2004, http://www.furcommission.com/resource/perspect999bz.htm .
[51] Inside the Fur Industry: Factory Farms , PETA, http://www.peta.org/mc/factsheet_display.asp?ID=56 (last visited Sept. 5 , 2010).
[52] 7 U.S.C. § 2132 (2002) .
[54] 16 U.S.C. §§ 3371 - 3378 .
[55] Jennifer O'brien & Randall Szabo, 2009 Legislative Review , 16 Animal L. 371, 376 (2010).
[56] 16 U.S.C. §§ 115 1-1187 .
[57] 16 U.S.C. §§ 136 1-1421h.
[58] 16 U.S.C. § 1371(a)(1) (1994) .
[59] H.R. 1054, 111 th Cong. (2009).
[60] Sen. 1395, 111 th Cong. (2009); see also O'brien & Szabo, supra note 55, at 373.
[62] 15 U.S.C.A. § 69 (2000) .
[63] 155 Cong. Rec. E 1200 (daily ed. May 19, 2009) (statement of Rep. Moran).
[64] House Passes Truth In Fur Labeling Act , Humane Soc ' y Legislative Fund, ( July 28, 2010 ) , http://hslf.typepad.com/political_animal/2010/07/truth-in-fur-labeling-act-passes-house.html .
[65] Truth in Fur Labeling Act of 2010, H.R. 2480, 111 th Cong. (2010).
[66] H.R. 2480.
[67] O'brien & Szabo, supra note 55 , at 380.
[68] Id. at 381.
[69] 19 U.S.C. § 1308 (2000) .
[70] 16 U.S.C. §§ 1531 -1541 .
[71] 16 U.S.C. § 1538(b)(1) (1988) ; Facts About Canned Hunts , Humane Soc ' y of the U . S . , http://www.hsus.org/wildlife/stop_canned_hunts/facts_about_canned_hunts.html (last visited Sept. 6 , 2010).
[72] Fur Farming in North Americ a, supra note 18 .
[73] Wis. Stat. § 29.627 (2004) .
[74] Mich. Comp. Laws § 324.43101 (199 9 ) .
[75] Cal. Civ. Code § 996 (West 1941) .
[76] Idaho Code Ann. § 25-3001 (2006) .
[77] Idaho Code Ann. § 25-3005 ( 2010 ) .
[78] Minn. Stat. § 17.353 (1985) .
[79] Mont. Code Ann. §§ 87-4-1001 - 87-4-1002 .
[80] Born Free USA, Cruelty Uncaged: A Review of Fur Farming in North America, 17 (November 2009).
[81] Monica Engebretson & Gil Lamont, The Commercial Wildlife Trade: An American Disgrace , 39 Animal Issues 3 (Fall 2008), available at http://www.bornfreeusa.org/articles.php?p=1815&more=1 .
[82] CO CONST Art. 18, § 12b .
[83] N.J. Stat. Ann. § 23:4-22.1 (West 19 97 ).
[84] Wash. Rev. Code § 77.15.194 (West 2003).
[85] Mass. Gen. Laws Ann. 131, § 80A ( West 200 2 ) .
[86] Ariz. Rev. Stat. Ann. § 17-301 (1998) .
[87] R.I. Gen. Laws § 20-16-8 (1981) .
[88] Md. Code Ann. Nat. Res. § 10-408.1 (West 1990).
[89] Cal. Fish & Game Code § 4004 ( West 1989) .
[90] N.Y. Envtl. Conserv. Law § 11-1101 ( McKinney 1991 ).
[91] Iowa Code § 481A.92 (1999) .
[92] Wyo. Stat. Ann. § 23-2-303 (2009).
[93] Bartlett v. State of Florida , 929 So. 2d 1125, 1126 (Fla. Dist. Ct. App. 2006) .
[94] Id . Section 828.12(2) holds accountable a person who intentionally commits an act that causes an animal to die a cruel death. Id .
[95] Id .
[96] Ala. Code §13A-11-14 (2010) .
[97] Ariz. Rev. Stat. Ann. § 13-2910(C)(3) (2002) .
[98] Idaho Code Ann. § 25-3514 (2010).
[99] Conn. Gen. Stat. § 53-247( b) (2004).
[100] Tex. Penal Code Ann. § 42.09 (Vernon 2007) .
[101] N.Y. Agric. & Mkts. Law § 353-c (200 7 ) .
[102] Cal. Penal Code § 597u (West 2005) .
[103] 11 Del.C. § 1325A (20 08 ) .
[104] N.J. Stat. Ann. § 56:14-1 (2009) .
[105] Wis. Stat. Ann. § 100.35 ( 1951 ) .
[106] Mass. Gen. Laws Ann. 94, § 277 A (1941) .
[107] N.Y. Gen. Bus. Law § 399- aaa (2007) .
[108] Justin Ho, Fur-Labeling Bill Passes Senate, to Governor , San Francisco Chronicle , Aug. 12, 2010, available at http://www.sfgate.com/cgi-bin/article.cgi?f=/c/a/2010/08/11/BAN31ESNNK.DTL .
[109] Ala. Code § 13A-11-241 (2000) .
[110] 11 Del. Code Ann. § 1325A (2000) .
[111] N.J. Stat. Ann. § 4:22-25.3 (1999) .
[112] N.Y. Agric. & Mkts. Law § 379 (2002) .
[113] 73 Pa. Cons. Stat. § 210-3 (2001) .
[114] Va. Code Ann. § 3.2-6589 ( 2008 ) .
[115] Va. Code Ann. § 3.2-6570 (2008) .
[116] Fla. Stat. § 828.123 (2000) .
[117] Or. Rev. Stat. Ann. § 167.390 (1999) .
[118] Engebretson & Lamont, supra note 81.
[119] EIA & WSPI, Skinning the Cat: Crime and Politics of the Big Cat Skin Trade 2 ( 2006) http://www.eia-international.org/files/reports129-1.pdf .
[120] EIA & WSPI, Skinning the Cat: Crime and Politics of the Big Cat Skin Trade 15 ( 2006) http://www.eia-international.org/files/reports129-2.pdf [hereinafter EIA & WSPI Part II].
[121] EIA & WSPI Part II , supra note 121, at 20 .
[122] Illegal Tiger Trade Must End , Humane Soc ' y Int ' l, http://www.hsus.org/hsi/wildlife/wildlife_trade/tiger_conservation/illegal_tiger_trade_11608.html .
[123] Id.
[125] Platt, John, Minor Victories for Tigers, Elephants and Rhinos at CITES Meeting , Basic Science, ( Mar. 24, 2010 ) , http://www.scientificamerican.com/blog/post.cfm?id=minor-victories-for-tigers-elephant-2010-03-24 .
[126] CITES Summary: Wildlife Win Some, Lose Some, http://hsus.typepad.com/wayne/2010/03/cites.html (Mar. 25, 2010, 4:27 EST).
[128] Council Directive 98/58/EC 1998 O.J. (L 221), art. 3.
[129] Council Directive 93/119/EC 1993 O.J. (L 340), Annex F, amended by Council Regulation (EC) 806/2003, 2003 O.J. (L 122).
[130] Fur Farming Legislation Around the World , Fur Free Alliance, http://www.infurmation.com/furfarmlegislation.php (last visited Sept. 6 , 2010).
[132] Israel Fur Trade Ban Wins Support , Humane Soc ' y Int ' l, ( July 19, 2010 ) , http://www.hsi.org/world/united_kingdom/news/news/2010/07/Israel_fur_ban_support_071910.html .
[133] Council Regulation (EEC) No. 3254/91 of 4 November 1991, 1991 O.J. (L308).
[134] Opinion of the European Economic and Social Committee (COM) No. 183/2004 of 16 December 2004, 2004 O.J. (C 157).
[135] Council Directive 89/370 , 198 9 O.J. (L 163 ) (EEC) .
[136] Fast Facts on Canada's Commercial Seal Slaughter , Humane Soc ' Int ' l, ( Feb. 25, 2006 ) , http://www.hsi.org/issues/protect_seals/research/seal_hunt_facts.html .
[137] Canada, Norway Launch WTO Complaint Over EU Seal Ban, Int'l Centre for Trade and Sustainable Dev . , ( Nov.13, 2009 ) , http://ictsd.org/i/news/biores/59391/ .
[139] Council Regulation 1007/2009, 2009 O.J. (L286/36) (EC) ; see also James G. Neuger, Canada Seal Hunters Win Court-Ordered Reprieve From European Union Ban , Bloomberg , (Aug. 20, 2010), http://www.bloomberg.com/news/2010-08-20/canadian-seal-hunters-win-court-ordered-reprieve-from-european-union-ban.html .
[140] Help Pass the Israeli Fur Ban , Born Free USA, ( Aug. 13, 2010 ) , http://bfusa.convio.net/site/MessageViewer?em_id=4901.0&dlv_id=8221 .
[141] Mackay, Mairi, Israel Debates Move to Ban Fur Trade, CNN, ( Mar. 17, 2010 ) , http://www.cnn.com/2010/WORLD/meast/03/17/israel.fur.ban/index.html .
[142] Id .
[143] Council Regulation 1523/2007, 2007 O.J. (L343) 1.
[144] 19 U.S.C.A. § 1308 (2000) .
[145] Dog and Cat Fur Trade , Humane Soc ' y Int ' l , http://www.hsi.org.au/?catID=160 (last visited Sept. 6 , 2010).
[146] Press Release, Int ' l Fur Trade Fed . , The Fur Trade Does Not Oppose EU Ban on Cat and Dog Fur, (June 19, 2007), available at http://www.iftf.com/#/press-releases/18/ .
[147] Labeling , Int ' l Fur Trade Fed . , http://www.iftf.com/#/labelling/ (last visited Sept. 6 , 2010).
[148] What is CITES? , Convention on Int ' l Trade in Endangered Species of Wild Fauna and Flora, http://www.cites.org/eng/disc/what.shtml (last visited Sept. 6, 2010).
[149] Member Countries, Convention on Int ' l Trade in Endangered Species of Wild Fauna and Flora http://www.cites.org/eng/disc/parties/index.shtml (last visited Sept. 6, 2010).
[150] The European Community and Trade in Wild Fauna and Flora , European Comm ' n, http://ec.europa.eu/environment/cites/home_en.htm (last visited Sept. 6, 2010).


On 23rd February, 2019, the Department for Promotion of Industry and Internal Trade ("the DPIIT") released the Draft National E-Commerce Policy ("the Draft Policy") with the objective to help stakeholders fully benefit from opportunities arising from the progressive digitization of the domestic digital economy and establish a level playing field for all stakeholders in the digital economy.
On 23rd February, 2019, the Department for Promotion of Industry and Internal Trade ("the DPIIT") released the Draft National E-Commerce Policy ("the Draft Policy") with the objective to help stakeholders fully benefit from opportunities arising from the progressive digitization of the domestic digital economy.
We at SFLC.in conducted a series of multi-stakeholder round table discussions on the Data Protection Bill, 2018 submitted by the Expert Committee on Data Protection headed by Justice (Retd.) B.N. Srikrishna.
The Ministry of Electronics and Information Technology has sought comments on the Draft Personal Data Protection Bill, 2018 by the 30th of September 2018.
The Ministry of Electronics and Information Technology has sought comments on the Draft Personal Data Protection Bill, 2018 by the 30th of September 2018. We are holding a Round Table discussion on the draft Bill on 25 September 2018 (Tuesday) at the Hyatt Centric Hotel, MG Road, Bengaluru from 10.30am to 4.30pm.


This weekend sees the penultimate round of this year's IFSC Bouldering World Cup taking place at Cliffhanger in Millhouses Park, Sheffield.
This years bouldering world cup has been an amazing year with both the Men's and Women's categories finely balanced going into the last 2 rounds. You can watch highlights of the Moscow round below and get psyched for some of the world's best boulderers crushing on the purpose built bouldering wall.
We're one of the sponsors of Cliffhanger and we'll be there with a climbing wall running improver sessions all weekend alongside FiveTen athlete, and general hero, Steve McClure. We're also going to be bringing the weekend to a big end with a party on the Sunday night at Alpkits big shake out area. We'll let you know how to get tickets, when & where, info on the sessions, etc.. tomorrow on our website & blog.
On tomorrow's blog as well, you'll find out about some of the physical changes that are about to happen within The Climbing Works reception area. It's been 3.5 yrs since we opened and we think the place needs a bit of a facelift.


The Whirl is held at the Fayette County Park in Beckwith, a wide place in the road eight miles west of Fayetteville and the bridge over the New River Gorge. We'll be dancing in a wonderful wood and stone New Deal-era dance hall with a suspended wooden floor, stage, fireplace and barn door sides that can be opened or closed to suit the weather.
We'll have a full schedule of workshops posted here by February 1, with Gaye, Bradley and others as workshop leaders.
On-site accommodation is included in the registration fee—your choice of a bunk bed in a cabin (foam mattress) or tent space. No reservation needed. Toilet and shower facilities are near the cabins. It's rustic, but comfortable.
If you still have energy left after dancing, head down the road to Fayetteville, one of the coolest outdoor adventure towns in the East with whitewater rafting, rock and cliff climbing, zip-lining, hiking, mountain biking (and some great restaurants). Or just take in the spectacular views from one of the trails in the New River Gorge.
If you can join us by 6 pm Friday, we will have a light dinner for only $8. The rest of the meals for the weekend are in a package deal costing $60 so you won't have to leave the camp if you don't want to. Catering is by Café 110 from Oak Hill (just down the road from the camp) https://www.facebook.com/cafeoneten The food is always great and plentiful, with options for vegans and the gluten intolerant.
PLEASE HELP US SPREAD THE WORD! We have never completely filled up our floor for the weekend, so maybe this can be the first time. Join "The Friends of Whitewater Whirl" on Facebook https://www.facebook.com/groups/1403071313130438/ and invite your friends.


text:
Jurgen Klopp details how Liverpool front three have reacted to Diogo Jota's flying start
Mohamed Salah, Roberto Firmino and Sadio Mane have Diogo Jota as competition for their places - but Jurgen Klopp insists it is something they are enjoying
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Jurgen Klopp admits new signing Diogo Jota has broken up his Holy Trinity attack – and given Liverpool another Fab Four.
And as Jota prepares to face his old club Wolves for the first time since his £41million arrival in September, Klopp has confessed Mo Salah, Sadio Mane and Roberto Firmino are happy with the competition – even if none of them are guaranteed to start anymore.
Goal-hungry Jota has hit the ground running since his arrival at Anfield with nine goals in his 15 games so far to give Klopp a welcome headache with the Kop boss currently having more competition up front than anywhere else on the pitch.
Jota's instant impact has ruffled the normal order in Klopp's front line – with Firmino benched for the key Champions League win over Ajax in midweek and Mane.
That followed a strop by Salah after being substituted during the draw at Brighton by Mane who was himself left on the bench for over an hour at The Amex Stadium.
Jota has enjoyed a flying start to life at Liverpool (Image: Pool via REUTERS)
Liverpool boss Jurgen Klopp names Chelsea as his favourites to win Premier League title
Gini Wijnaldum admits uncertainty over Liverpool teammate Virgil van Dijk's injury
Jota started both those games – and Klopp insists having the razor-sharp 24-year-old Portugal international has given the champions a decisive advantage they didn't have last season.
"Mo, Sadio and Bobby Firmino have no problem with competition and Diogo as well," says Klopp. "Jota is doing exceptionally well.
"For us it was the most important thing for this season that we don't have to bite our nails pretty much each game like last time and hope somehow they come through it and we can bring them into the next game again.
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It's been an extremely interesting start to the season for Jurgen Klopp's men.
They got their title defence off to a shaky start as they edged out a seven-goal thriller against Leeds, before going on to conceded seven in a hammering by Aston Villa.
Virgil van Dijk's season was ended by injury in the 2-2 draw at Everton, leaving the title favourites looking far less secure at the back - especially with Alisson's injury worries too.
But there's no slowing down in what is going to be a busy campaign - with Klopp ensuring his men continue at full pace as they bid for more title glory.
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"It's not a real luxury situation because it's only one extra player but its the only position at the moment, the only line, the front three line, where we have more players than we can line up in one game.
"All the other positions are pretty much who can walk will play or it will be a kid.
"So there is nothing bad in this situation for anyone, they all deal with it. They wouldn't be who they are or where they are if they couldn't deal with a situation like this.
"They are completely fine with it. And they are happy Jota has had that brilliant start as I am obviously."
Liverpool will be allowed 2,000 of their fans into Anfield for the first time since Project Restart. But although delighted to see them back Klopp isn't expecting them to suck the ball into the net like the Kop in full flow.
"Having fans back is great but how it helps I'm not sure. Will it help us against Wolves? I don't know we will see.
"I'm happy for those people who will be in the stadium. But do I expect that 2,000 people will push us through a difficult game and we win because of that? No I don't."
Georginio WijnaldumGini Wijnaldum's Barcelona "dream" is a pull Liverpool can't match, says Danny MurphyThe Dutch midfielder is into the final six months of his Anfield deal, and would appear to have his heart set on a summer switch to the Nou Camp
Ex-Man Utd coach tells Donny van de Beek "there are plenty of other clubs" out there
Donny van de BeekEver since Donny van de Beek signed for Man United in the summer he has received advice from former professionals back home, disappointed he isn't playing every week

redpajama_set_name: RedPajamaCommonCrawl


Kayaking is one of the best ways to enjoy the beautiful surroundings – explore the peaceful and quiet waterways of the Raglan/Whaingaroa harbour.
With kayaks locally available to hire, including both single and tandem options, there is no reason not to give it a go!
Local operators organise a range of tours for individuals and groups.
To find out more about rentals and excursions, visit www.raglankayak.co.nz or www.raglanwatersports.co.nz.


How public consultation on Cedar Hill Golf Course costs will be carried out is not yet clear, but it should be by the end of March, Mayor Frank Leonard said Wednesday.
The consultation is part of a motion that passed after a fiery public meeting Tuesday night about how to deal with a $300,000 deficit in golf course operations at the municipallyowned Cedar Hill course.
"It will be treated like any other rec centre where managers resolve operational issues with users and the public, and we [the council] look at the bottom line once a year," Leonard said.
Val Mieras, president of the Cedar Hill Golf Club, said what the consultation will translate to is a mystery to many who attended the meeting, and they are not happy.
Hundreds of residents attended three public meetings, held after Saanich council decided unanimously and in camera to close the golf course restaurant.
It was estimated to lose $521,000 in 2012, so council voted to reduce its full service to a "grab-and-go" style. The restaurant closed its doors last Saturday.
The council said it was done in camera because it dealt with personnel issues.
Since then, the three public meetings held to allow public input on municipal staff recommendations on how to deal with the $300,000 deficit have grown increasingly tense between the public and the council, and also among the politicians.
But the motion came with little clarity on how the engagement would happen, said Coun. Dean Murdock, one of the four who voted against it.
He asked that staff report back to council on how the engagement would take place, but that was dismissed.
This entry was posted in Issues and Ideas and tagged golf course, public engagement, recreation on February 24, 2012 by Dean Murdock.
Saanich council split 5-4 in favour of increasing fees at Cedar Hill Golf Course after a heated public meeting Tuesday night.
Full season pass holders will see a five per cent increase each year for the next three years, along with a decrease in the number of rounds they can play between April 15 and Oct. 15. A 2011 pass cost 1,350 and will rise to $1,417.50 in 2012, with another 5 per cent increase in 2013 and in 2014. The daily green fee will go up $9 over the next three years, starting with a $5 increase in 2012.But the actual fee increase was not the most contentious issue for the 200 people who came out to the third public meeting to talk about the growing deficit at the municipally owned golf course.
Many at the meeting were angry about lack of public consultation in dealing with financial problems at the golf course and restaurant.
The municipally owned facilities were projected to lose more than $800,000 in 2012. Both have been losing money for the past several years.
In January, council voted unanimously in favour of closing the full-service restaurant, which was projected to lose $521,000 this year, and replacing it with light food service. That decision was made at an in-camera meeting because personnel issues were also being discussed.
The restaurant, loved by many residents throughout the region but unknown to as many others, closed Saturday.
Many on Tuesday said they were surprised to learn about the financial difficulties at the restaurant and golf course and said they felt "blindsided" by the in-camera decision to close the restaurant.
Some speakers were in tears, while others shouted for the resignation of management and council.
Still others called for a six-month reprieve for the restaurant and many had suggestions for improving how the facilities are run.
Coun. Nichola Wade made a motion that recommended the fee increases, but also called for staff to have public consultation with golf users and the public to discuss how operations could be improved, keeping in mind the need for debt reduction. Staff will report back to council on those discussions.
The motion narrowly passed, with a deep split on council. Wade, councillors Paul Gerrard, Leif Wergeland and Susan Brice and Mayor Frank Leonard voted in favour of the motion.
Councillors Dean Murdock, Vic Derman, Vicki Sanders and Judy Brownoff voted against it, preferring a facilitated public consultation on all financial issues facing the operation, including food services.
If you plan to hit the links at the Cedar Hill golf course, expect to shell out more money come April.
Saanich council voted Tuesday night to support a rate increase for pass-holders and green fee players to help reduce a massive $820,000 deficit facing the course and clubhouse.
But the heated budget meeting, a continuation of one that began on Feb. 7, saw 30 speakers address council on a number of concerns, many who feel a happy golfing experience won't be achieved with these approved changes.
For pass-holders, that's because they'll have to pay more to get less.
Council supported a $68 increase to $1,418 for a full annual pass, which allows pass-holders to play on the weekends. A restricted pass will increase by $37 to $1087, and holders can only play Monday through Thursday.
While last year's full pass allowed a maximum of 120 rounds per year, this year's more expensive pass would only allow for 90 rounds annually. There are restrictions on how many rounds pass-holders can play each week, and how many can be played in the summer.
Green fees will also increase by $5 this year, and $2 each year in 2013 and 2014.
Closing the restaurant at Cedar Hill golf course, which happened last Friday, will have a $98,000 impact on this year's operating budget. But when the entire course – including golf and food services – is operating at an $818,000 deficit (including debt) in 2012. Saanich projects the course to earn $1.37 million this year, while it runs at a cost of $2.09 million.
Tuesday night's meeting, held at the Garth Homer Society, with more than 150 residents in attendance, saw council split 5-4 on the decision to increase fees.
Four councillors, who told the News earlier this month that their in-camera decision to close the golf course restaurant was a "mistake", having not consulted with the public, opposed the fee increase and instead opted to attempt to start a consultation process before making any more decisions. That failed.
Coun. Nichola Wade garnered support from three of her fellow councillors and the mayor to approve the fee increases, then subsequently begin consulting with the public.
"It's like talking to a wall," Mieras said. She, along with other members of the golf club, have been invited to 'stakeholder meetings' with Saanich management over the last couple months to provide input on the changes.
Since the get-go, she says there's been strong opposition to the "pay more, get less," and she feels like the golf course's loyal customers are being ignored.
"Silence is deafening," Camrose Crescent resident Kevin Moore told council, upon asking for anyone in the 150-plus-member audience to applaud if they supported the decisions council had made with regards to the golf course.
Mayor Frank Leonard reassured the unhappy crowd that, as part of the approved recommendation, council will monitor how the changes are impacting the financial situation at the golf course.
"If this isn't working, we need to find out quick," he said.
Mieras said she's concerned that council's approval to increase fees without starting the consultation process beforehand will drive business away.
A staff recommendation to increase green and pass fees while offering pass holders a reduced number of rounds at the Cedar Hill Golf Course, was passed by a slim majority of Saanich Council members Tuesday night.
The recommendation was made in response to a deficit facing the municipally owned golf course.
Saanich Councillor Dean Murdock says 4 councillors and the mayor supported the recommendations, and 4, including himself, opposed it.
Murdock says in his opinion, dealing with fees isn't enough to ensure the courses' sustainability.
Murdock says fees would be set for the next three years, but there has been a request that staff report back on fees annually.
Murdock says the new fees take effect April 1st, 2012.
A second special meeting of Saanich Council for public input into the sustainability of the Cedar Hill Golf Course is set for tonight.
The issue has been a hot-topic in the municipality after it was announced that the district-owned course was facing a $300,000 dollar deficit.
Councillor Dean Murdock sees the public consultation as an opportunity.
Council will be asked to vote on a recommendation from staff following the public input tonight. That report suggests green and pass fees be increased, while offering pass-holders a reduced number of rounds.
The meeting is scheduled for 7:30 tonight at the Garth Homer Centre.
This entry was posted in Issues and Ideas and tagged golf course, public engagement on February 24, 2012 by Dean Murdock.
A quartet of Saanich councillors want to better engage the public on the future of the Cedar Hill golf course.
Judy Brownoff, Vic Derman, Dean Murdock and Vicki Sanders are expected Monday to ask for a facilitated public engagement process to formally gather input on the floundering course.
Brownoff said that the whole community, not just the golfers, should be consulted on any decisions made on the course's future.
Though much of the conversation of late has surrounded the restaurant's closure, Brownoff says it's unlikely that decision will be reversed.
Murdock says there are misunderstandings about council's closed-door decision, adding that the discussion surrounding it was very long.
"There's an impression created that this was something that was unanimously supported … and without getting into details, that was not my view of how that meeting transpired," he said.
The decision on the restaurant, which sparked the public outcry, was made in-camera because there were confidential personnel issues to discuss.
Monday's recommendation from the group of councillors will be during a public meeting, held at 7:30 p.m. at Saanich municipal hall (770 Vernon Ave.).
This entry was posted in Issues and Ideas and tagged golf course, open government, public engagement on February 4, 2012 by Dean Murdock.
Four Saanich councillors will ask the council to strike a committee to study the future of Cedar Hill Golf Course and to hold more targeted public meetings to deal with the deficit at the municipally owned course.
The motion by councillors Dean Murdock, Judy Brownoff, Vicki Sanders and Vic Derman will go to council Monday night.
Murdock said it became clear this week, after more than 300 people packed a Monday night meeting, that there is great public interest in the future of the course, a fixture in the municipality for 80 years.
The golf course and its restaurant were projected to lose $820,000 in 2012. Saanich decided last month to close the full-service restaurant and replace it with light refreshments, but that still left the problem of the golf course, which is losing taxpayer money.
Saanich parks and recreation management held Monday's meeting to gather input from the public. The "town hall" style is not conducive for people to have a chance to speak, let alone express all their thoughts, Murdock said. Several meetings, perhaps with specific topics for each one, might be a better way to gather help from residents, he said.
Meetings and the formation of a committee should take place relatively quickly, to take advantage of the current interest and to find a solution so taxpayers' money isn't wasted, Murdock said.
There is a great deal of expertise and creativity among Saanich residents on how to deal with the problem and smaller meetings would allow that to be more easily communicated to staff, he said.
Saanich holds a budget meeting on Tuesday, at which the golf course will be discussed. Another venue is being sought, instead of council chambers, given the turnout at this week's meeting.


text:
<?php
namespace Ojs\UserBundle\Listeners;

use Doctrine\ORM\Event\LifecycleEventArgs;
use Ojs\Common\Params\ProxyEventLogParams;
use Ojs\UserBundle\Entity\EventLog;
use Ojs\UserBundle\Entity\Proxy;
use Symfony\Component\HttpFoundation\RequestStack;
use Symfony\Component\HttpFoundation\Response;

class ProxyListener
{
    /** @var RequestStack */
    protected $request;

    /**
     * @param RequestStack $request
     */
    public function __construct(RequestStack $request = null)
    {
        $this->request = $request;
    }

    /**
     * Every new proxy create event log to event log
     * @param  \Doctrine\ORM\Event\LifecycleEventArgs $args
     * @link http://docs.doctrine-project.org/en/latest/reference/events.html#postupdate-postremove-postpersist
     * @return Response                               never null
     */
    public function postPersist(LifecycleEventArgs $args)
    {
        if (php_sapi_name() != 'cli') {
            $entity = $args->getEntity();
            $entityManager = $args->getEntityManager();

            /**
             * perhaps you only want to act on some "Proxy" entity
             * @link http://docs.doctrine-project.org/en/latest/reference/events.html#listening-and-subscribing-to-lifecycle-events
             */
            if ($entity instanceof Proxy) {

                //log as eventlog
                $event = new EventLog();
                $event->setUserId($entity->getClientUser()->getId());
                $event->setEventInfo(ProxyEventLogParams::$PROXY_CREATE);
                $event->setAffectedUserId($entity->getProxyUser()->getId());
                $event->setIp($this->request->getCurrentRequest()->getClientIp());
                $entityManager->persist($event);

                $entityManager->flush();
            }
        }
    }

    /**
     * Proxy drop event event log function.
     * @param  LifecycleEventArgs $args
     * @return null
     */
    public function preRemove(LifecycleEventArgs $args)
    {
        if (php_sapi_name() != 'cli') {
            $entity = $args->getEntity();
            $entityManager = $args->getEntityManager();

            /**
             * perhaps you only want to act on some "Proxy" entity
             * @link http://docs.doctrine-project.org/en/latest/reference/events.html#listening-and-subscribing-to-lifecycle-events
             */
            if ($entity instanceof Proxy) {

                //log as eventlog
                $event = new EventLog();
                $event->setEventInfo(ProxyEventLogParams::$PROXY_DROP);
                $event->setIp($this->request->getCurrentRequest()->getClientIp());
                $event->setAffectedUserId($entity->getProxyUserId());
                $event->setUserId($entity->getClientUserId());
                $entityManager->persist($event);

                $entityManager->flush();
            }
        }
    }
}

redpajama_set_name: RedPajamaGithub


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Feng Shui teaches the importance of becoming more present and aware of your surroundings. In the practice of Feng Shui your home is metaphor of your life and the artwork you choose to display (consciously or subconsciously) is telling a story, conveying a mood, an idea and stirring up emotions.
Art is highly subjective and what inspires one person may be uninspiring to another. So this is why it's important to understand your intentions (the reasons) for why you are choosing to transform your home and life.
Below are Feng Shui principles to consider when choosing art.
Select artwork that is appropriate in size for the wall, the room and the furnishings. Even this helps to create harmony.
To select the type of artwork, become clearer with your intentions for why you are selecting artwork in the first place. Is it to represent a change in love? in career? in health? Based on that, you could then move to selecting certain colors, shapes, artists, themes and more to help narrow down your choices.
The act of choosing artwork and selecting the style and subject matter that peaks your interests is allowing you to get to know yourself. There is a deeper approach then just hanging artwork. It helps to visually display your values and dreams.
I'm personally not a fan of store bought mass produced artwork, which I did start off with until I graduated to a much more personalized touch and collection. The artwork that currently resides inside my home consists of pieces created by family and friends, art purchased from local villages and towns from my travels and artwork that I personally created. Each piece has a story, a rich meaning and strong positive emotional connection.
When was the last time you truly observed the story being told inside your home?
A foundational suggestion in Feng Shui is to select furniture that has rounded designs or soft edges. Why is that? In the terms of Feng Shu, rounded designs and soft edges help to generate "Sheng Chi." This type of ch'i mimics the natural designs of nature and offers a stronger opportunity for life force energy to flow throughout your home with ease.
For the more analytical minds we now have scientific proof that supports the importance of this tangible Feng Shui suggestion.
Experiments conducted in 2010 and 2013 by neuroscientists from the Zanvyl Krieger Mind/Brain Institute at Johns Hopkins University and the Walters Art Museum in Baltimore, the University of Toronto at Scarborough and a study published in the National Academy of Sciences have all concluded the same results with quantifiable data.
What shapes are most pleasing and what exactly is happening in our brains when we look at them?
"We wanted to be rigorous about it, quantitative, that is, try to really understand what kind of information neurons are encoding and…why some things would seem more pleasing or preferable to human observers than other things. I have found it to be almost universally true in data and also in audiences that the vast majority have a specific set of preferences," says Charles E. Connor, director of the Zanvyl Krieger Mind/Brain Institute.
The studies concluded participants viewing organic forms (like artwork from Jean Arp), architecture and interior decor with rounded shapes demonstrated increased brain activity. Verbally, participants used words like "beautiful" and "pleasing" to describe what they saw.
So why do humans prefer rounded shapes vs sharp and jagged edges?
Does this mean your entire home needs to be full of rounded things? No. Yet it does mean, it's strongly suggested to have a balance of rounded designed items and furniture to generate a more positive feeling and brain stimulation.
Smithsonian Magazine - Do Our Brains Find Certain Shapes Then Others?


text:
/**
 * File: triangle.c
 *
 * Module for defining 3-D models.
 */
#include "triangle.h"

#include <stdint.h>
#include <math.h>
#include <stdbool.h>
#include <stdio.h>

#include "point.h"
#include "util.h"

/**
 * Function: Triangle_getBaryColor
 * Gets the color for a point on the triangle based on it's barycentric coordinates.
 *
 * Arguments:
 *  pThis   -   const <Triangle_t>* : Pointer to the triangle.
 *  opColor -   <Color_t>* : Pointer to the object that will hold the output color.
 *  pBary   -   const <Point_t>* : A point containing the barycentric coordinates of the point.
 */
static Color_t * Triangle_getBaryColor(const Triangle_t *const pThis, Color_t *const opColor, const Point_t *const pBary)
{
    const double r = (pBary->x*(pThis->vert[0].color.r)) + (pBary->y*(pThis->vert[1].color.r)) + (pBary->z*(pThis->vert[2].color.r));
    const double g = (pBary->x*(pThis->vert[0].color.g)) + (pBary->y*(pThis->vert[1].color.g)) + (pBary->z*(pThis->vert[2].color.g));
    const double b = (pBary->x*(pThis->vert[0].color.b)) + (pBary->y*(pThis->vert[1].color.b)) + (pBary->z*(pThis->vert[2].color.b));

    return Color_cfg(opColor, r, g, b);
}

double Triangle_rayCast(const Triangle_t *pThis, Color_t *opColor, const double closest_dist, const Point_t *const pt, const Vect_t *const vect)
{
    Vect_t disp;
    Vect_t pointer;
    Point_t intersection;
    Point_t bary;

    //A point on the plane of the triangle.
    const Point_t *const pop = &(pThis->vert[0].loc);

    //Convenient handle to the plane-normal.
    const Vect_t *const pNorm = &(pThis->normal);

    // What we're doing here is intersecting a ray with a plane.
    // The vector is a parametric equation like: pt + t*vect, so what we're going
    // to find is the value of t for which the ray and the plane coincide.
    // This is done as t = (disp . norm) / (vect . norm), where disp is a vector
    // from the start of the ray to any point on the plane.

    //Get the denominator for the distance calc.
    const double denom = Vect_dot(vect, pNorm);
    if (denom == 0) {
        //Line and plane are parallel, no intersection (or infinite intersection).
        return closest_dist;
    }

    // Finish the distance calc.
    Point_displacement(&disp, pt, pop);
    const double numer = Vect_dot(&disp, pNorm);
    const double dist = numer / denom;

    //If t is negative, then the intersection if "behind" the starting point of the ray, so there is no intersection.
    // Or, if the intersection is further away than a point we've already hit with the ray, then we don't care about this
    // one, we use the other one.
    if(dist < 0 || dist >= closest_dist) {
        return closest_dist;
    }

    //Pointer from pt to the intersection.
    Vect_scale(&pointer, vect, dist);

    //Point of intersection.
    Point_translate(&intersection, pt, &pointer);

    //Get the barycentric position of the intersection.
    Triangle_barycentricPosition(pThis, &bary, &intersection);

    //If any of it's components are negative, it is outside of the triangle, so no intersection.
    if(bary.x < 0 || bary.y < 0 || bary.z < 0) {
        return closest_dist;
    }

    //Get the color of the intersection point.
    Triangle_getBaryColor(pThis, opColor, &bary);

    //This is now the closest distance.
    return dist;
}

/**
 * Function: Triangle_signedArea
 * Gets the signed area of a triangle defined by three points, relative to an orientation
 * defining normal vector.
 *
 * The triangle is defined by the three point vetices, A, B, and C. The given normal vector
 * should be (approximately) normal to the triangle and indicates what orientation is considered
 * to have positive area versus negative area. When looking along the direction of the vector,
 * if the vertices A, B, and C are arranged clockwise (in that order) then the are is positive,
 * otherwise it is negative. I'm pretty sure I got that right, otherwise it's the reverse.
 */
static double Triangle_signedArea(const Vect_t *const pNorm, const Point_t *const pA, const Point_t *const pB, const Point_t *const pC)
{
    Vect_t ab, ac, xp;

    //Get vectors.
    Point_displacement(&ab, pA, pB);
    Point_displacement(&ac, pA, pC);

    Vect_cross(&xp, &ab, &ac);

    const double xpl = Vect_dot(&xp, pNorm);

    return 0.5 * xpl;
}

bool Triangle_isInside(const Triangle_t *const pThis, const Point_t *const pPt)
{
    Point_t bary;
    Triangle_barycentricPosition(pThis, &bary, pPt);
    if(pPt->x < 0 || pPt->y < 0 || pPt->z < 0) {
        return false;
    }
    return true;
}

Point_t * Triangle_barycentricPosition(const Triangle_t *const pThis, Point_t *const opBarry, const Point_t *const pPoint)
{
    const Point_t *const a = &(pThis->vert[0].loc);
    const Point_t *const b = &(pThis->vert[1].loc);
    const Point_t *const c = &(pThis->vert[2].loc);

    const double pbc = Triangle_signedArea(&(pThis->normal), pPoint, b, c);
    const double pca = Triangle_signedArea(&(pThis->normal), a, pPoint, c);
    const double pab = Triangle_signedArea(&(pThis->normal), a, b, pPoint);

    return Point_cfg(opBarry, pbc / pThis->area, pca / pThis->area, pab / pThis->area);
}

Triangle_t* Triangle_cfg(Triangle_t *const pThis, Vertex_t *const pVertex1, Vertex_t *const pVertex2, Vertex_t *const pVertex3)
{
    Vertex_copy(&(pThis->vert[0]), pVertex1);
    Vertex_copy(&(pThis->vert[1]), pVertex2);
    Vertex_copy(&(pThis->vert[2]), pVertex3);

    Vect_t u, v;
    Point_displacement(&u, &(pVertex1->loc), &(pVertex2->loc));
    Point_displacement(&v, &(pVertex1->loc), &(pVertex3->loc));
    Vect_cross(&(pThis->normal), &u, &v);
    Vect_normalize(&(pThis->normal), &(pThis->normal));

    pThis->area = Triangle_signedArea(&(pThis->normal), &(pVertex1->loc), &(pVertex2->loc), &(pVertex3->loc));

    return pThis;
}

Triangle_t* Triangle(Vertex_t *const pVertex1, Vertex_t *const pVertex2, Vertex_t *const pVertex3)
{
    Triangle_t *pThis = Util_allocOrDie(sizeof(Triangle_t), "Allocating new Triangle_t object.");
    if(pThis != NULL) {
        Triangle_cfg(pThis, pVertex1, pVertex2, pVertex3);
    }
    return pThis;
}

Triangle_t* Triangle_clone(const Triangle_t *const pRhs)
{
    return Util_cloneOrDie(pRhs, sizeof(Triangle_t), "Cloning Triangle_t object.");
}

Color_t * Triangle_getColor(const Triangle_t *const pThis, Color_t *const opColor, const Point_t *const pPt)
{
    Point_t bary;
    Triangle_barycentricPosition(pThis, &bary, pPt);
    return Triangle_getBaryColor(pThis, opColor, &bary);
};


text:
← On the Pulse Nightclub Massacre
The Lowlights of the Mike Pence Speech →
Posted on July 7, 2016	by Callen Harty
Sign at a rally after the Michael Brown shooting. Photo by Callen Harty.
Sometimes violence in a family is generational. A father beats a son who beats his son who beats the next son because that is the world in which each of the sons grew up and that is how they learned to deal with conflict, frustration, and any other feeling that may come up in their lives. At some point one child may grow into a man and decide that the way he grew up was horrible and the last thing he wants to do is to inflict the same pain and abuse on his children, so he figures out a different way and breaks the cycle. He figures out how to discipline without violence and how to love fully and his children learn the same because that is the world in which they grew up.
I feel like America is that bully father and that unfortunately there are scant few who grew up here who want to break that cycle.
Today I woke up (again) to the news of a police officer shooting and killing a black man. This time it was in Minnesota during a traffic stop. It was a man who was told to show his ID, who informed the police up front that he had a concealed carry permit, and who was shot four times as he moved to get the ID he had been asked to show. His girlfriend and child were in the car and witnessed the horrible event.
Yesterday it was an officer in Louisiana who shot a man multiple times who was already on the ground in the arms of two police officers. He did have a gun, but it was in his pocket, where they pulled it from after he was shot.
A couple weeks ago it was a mad gunman who shot and killed nearly 50 people at a gay bar in Orlando. These horrible events keep happening and we keep crying for a moment and then forgetting. Last year in the United States there were more mass shootings than the number of days in a year.* Last year there were 493 murders just in the city of Chicago and this year is on a pace to beat that by a large number, with 336 murders already recorded in the windy city just a little over halfway into the year.**
Early in the year when a murder occurs in my city of Madison, Wisconsin the police and media will refer to it as Madison's first murder of the year, as if there is an expectation that there will be more–because that is the world in which we live.
We also live in a country that has become the world's bully. As a nation we take down or kill leaders of other countries, we bomb innocent civilians in a never-ending cycle of incursions, actions, and wars, we engage in war with several countries at a time, we kill first and ask questions later–just like these latest killings by the police.
Our founding fathers gained independence with a violent revolution. They enshrined the right to bear arms into our Constitution. They held people captive as slaves who could be beaten, raped, or killed on a whim. They committed genocide against the native population of this land. They created a lawless west. As a nation we have admired the most violent among us–outlaws of the west, gangsters in the early 20th century, Presidents and generals who lead us into unnecessary wars and are honored for it with peace medals.
The lessons we have learned as children of this nation are the lessons of violence. We have engaged in a litany of wars and military actions from George Washington all the way through Barack Obama. And virtually all our wars were fought not to protect American people, but American interests, which translates as protecting the wealth and assets of the ruling class. Not one generation has grown up without war. Every American child has grown up with our country engaged in killing other people in far-off lands, and we have grown to accept this as the normal course of things.
I believe that as long as our leaders continue to justify drone warfare, bombings with "collateral damage" , unnecessary and unjust wars, covert killings of supposed enemies, as long as we continue supplying the world with munitions and our own citizens with military-grade weapons, as long as there are classes of citizens who are considered "other" or "less than", as long as the signal from the top down continues to be that violence is resolution then we will continue to see police officers kill persons of color and poor white folks. We will continue to see mass shootings and daily murders in cities across the country. We will continue to see a descent into a world where no life has value.
The children of this country need to break the cycle. Those who understand that violence begets violence and love begets love must find a way to reach others, to reach our leaders, to change the way the world is now so that we can live in a future where everyone is safe, everyone is truly equal, and every life is valued. It is not just about removing guns from madmen. It is about changing the entire culture.
I wish I knew how that could be done. I wish I had an easy answer. I don't. I think it has to start within the hearts of those who value life more than property or wealth. It has to start with those who do not think color, gender, orientation, or a host of other factors make anyone less. I think those who want to see it change have to reach out and touch those with whom they are close, and then those people need to reach out to others, until there is a mass movement of citizens demanding that we look at the way we move through this world, both as individual citizens and as a government that is supposed to represent us. I think that those of us who want to see this change must start taking stands whenever and wherever we can. We need to stand up and say "No more." We have to let it be known that we will not accept things as they are, and that we expect things to be better. It will not change itself. It needs common people to stand up and demand something better.
*372 mass shootings (defined as four or more injured or killed) resulting in 475 deaths and 1,870 wounded according to 2015: The Year of Mass Shootings by Abbey Oldham. PBS News Hour. http://www.pbs.org/newshour/rundown/2015-the-year-of-mass-shootings/
**2015 Chicago Murders. Timeline. DNAInfo, Chicago. https://www.dnainfo.com/chicago
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