If not……. NOW is the Time to Make Your Voice Heard

Please Comment by April 10th

APHIS/USDA are asking for COMMENTS from individuals with expertise in animal care. This is a rare opportunity for veterinary professionals—like you—to share substantive comments with USDA that could help improve federal standards at large-scale commercial breeding farms. Veterinary professionals are uniquely positioned to provide the specific expertise APHIS/USDA is requesting.

Don’t be confused by the title of their request……

Wild and Exotic Animal Handling, Training of Personnel Involved with Public Handling
of Wild and Exotic Animals, and Environmental Enrichment for Species 

If you have wildlife expertise, great—but, if you don’t--the second part of this request refers to ALL SPECIES covered by the Animal Welfare Act. This includes puppies and breeding dogs who are licensed by the USDA.

If you want to make a difference, you have two options: 

  1. Quick Action: Follow this link to a page where you can simply sign onto a letter urging USDA to make changes to require enrichment for all species covered by the AWA and better protect wild animals and the public. Don’t forget to highlight your veterinary professional credentials!
2. More Detailed Comments: If you want to make more specific recommendations, here is a synopsis of the request from the Federal Registry:

“The most common concern regarding enrichment noted by APHIS inspectors of licensees exhibiting species other than non-human primates has been a complete lack of any enrichment or a barren environment, followed by single housing of social species, and an inability to express species-typical behaviors.”

Veterinary professionals can send comments to USDA via the Federal Register website

 Some suggested recommendations are:

  • Dogs need ample space to perform species-typical behaviors to take advantage of any environmental enrichment. USDA should at least triple the minimum enclosure sizes for dogs.
  • USDA must prohibit stacked, wire cages at commercial breeding facilities.
  • The unsanitary conditions these dogs and puppies live in, as well as transport conditions, have been linked to multidrug-resistant Campylobacter outbreaks.  We are sure many of you have seen  problems in your practices with coccidia and giardia infections due to the crowded, cage-stacking conditions many of these dogs/puppies live in, as well as the consequences of contaminated  water supplies—not to mention infectious diseases, especially those caused by respiratory pathogens.
  • Enrichment plans for dogs and cats must include improvements that are visible and measurable by inspectors. 
  • You can refer to the  Association of Shelter Medicine Guidelines for Standards of Care in Animal Shelters for additional suggestions and details. The primary enclosures section that starts on page 14 is especially pertinent. Examples from ASV on primary enclosures include:  
    • Animals must be able to make normal postural adjustments within their primary enclosures, including standing and walking several steps, sitting normally, lying down at full body length, and holding the tail completely erect. 
    • Enclosures must allow animals to sit, sleep, and eat away from areas of their enclosures where they defecate and urinate.  
    • Enclosures that include outdoor space must protect animals from adverse weather; provide choice for thermoregulation; protect from predators; and prevent escape, theft, or harassment.

Please add any other comments from your veterinary perspective, regarding environmental enrichment and conditions under which these animals are forced to live. Please contact [email protected] if you have questions about this request.

And remember: the deadline to submit comments is April 10th.

Thank you!