FTC Public Comments on HISA Proposed Medication Rules Due February 9th

Public comments to the FTC on the HISA proposed medication rules are due by 11:59 pm next Thursday, February 9th.

Below is the link to submit your comments;


Below you will find a sample submission to the FTC which you can simply copy and paste or make any changes you see fit to before submitting.

“As a horseman currently racing in Ohio. I am submitting comments asking the FTC
NOT to approve the proposed HISA Anti-Doping and Medication Control Rules. On
December 12, 2022, the FTC disapproved an almost identical version of this Rule
based on the fact the rules were not consistent with the Act which calls for the
establishment of uniformity in horse racing. The disapproval states clearly that
uniformity cannot be achieved until “the legal uncertainty regarding the Act’s
constitutionality comes to be resolved.” The Fifth Circuit recently declined to
revisit their opinion when asked to do so by the Authority and you, the FTC;
therefore, there is no doubt the legal uncertainty remains unresolved. The FTC
decision to disapprove the proposed ADMC Rules in December remains the correct
one now.

In addition to the continued uncertainty in the court system over the
constitutionality of this law, the proposed rules themselves have unworkable
issues which must be addressed. These rules were drafted without input from
horsemen or the practicing veterinarians who will have to live by them on a
daily basis should they be enacted. I’ve attached the National HBPA and NAARV
submission to the FTC which lay out numerous concerns horsemen nationwide have
with these proposed rules.

Without question, the vast majority of horsemen and horsewomen who are being
forced to race under the HISA regulations, DO NOT support HISA.”

Below is the National HBPA and NAARV joint submission to the FTC regarding these proposed rules which lay out the countless concerns horsemen nationwide have regarding these rule proposals. This file can be saved and attached to your FTC submisson.

2023 NHBPA_FTC ADMC Comments Posted 2.3.22