APHIS Seeks Public Comment on the Animal Care Policy Manual

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APHIS Seeks Public Comment on the Animal Care Policy Manual


Animal Care   October 17, 2007 


The Animal and Plant Health Inspection Service’s (APHIS) animal care (AC) program is undertaking a review of the existing Animal Care Policy Manual and welcomes public comment. APHIS will be accepting public comments through Nov. 16, 2007.


The policy manual is a guidance document developed primarily for AC field inspectors, and it is also provided to entities regulated under the Animal Welfare Act (AWA). It clarifies, interprets and/or provides examples of how to comply with existing AWA regulations or standards.


APHIS has designated the Animal Care Policy Manual a significant guidance document pursuant to the Office of Management and Budget’s (OMB) “Final Bulletin for Agency Good Guidance Practices” (72 FR 3432-3440). In order to increase the quality and transparency of agency guidance practices, OMB established policies and procedures for the develop-ment, issuance and use of significant guidance documents. Information about APHIS’ significant guidance documents and the agency’s guidance practices is available at http://www.aphis.usda.gov/guidance .


In keeping with the good guidance practices outlined in OMB’s bulletin, APHIS is seeking public comment on the manual, including recommendations for adding, changing or rescinding any policy that it contains. The AC program has always given due consideration to comments received from the public regarding the policy manual but is doing so now in a more formal manner.


The Animal Care Policy Manual may be viewed on the Regulations.gov Web site

http://www.regulations.gov. It will be available for public review and comment through Nov. 16. All comments received by that date will be given due consideration.


Carole’s Note:

Here is the direct link to the 88 page Policy Manual that they are asking for comment on:



Here are Carole’s comments if you would like to use them for reference:


USDA Animal Care Policy Comments


Policy #1


  1. License renewals should meet the same criteria as initial applicants in that no license should be renewed if the last inspection report cited deficiencies that were not corrected within 90 days. 
  2. Denial of a license to those who have been jailed for animal cruelty should also include those who have been jailed for any form of illegal trafficking of narcotics and weapons as these are often the same rings involved in the illegal trafficking of wildlife.
  3. Denial of license to those who are under investigation for animal cruelty should also include those who have been jailed for any form of illegal trafficking of narcotics and weapons as these are often the same rings involved in the illegal trafficking of wildlife.


Policy # 2


Exhibitors should be required to notify USDA ANY time regulated animals are taken off site from the licensed facility, except when they are being transported directly to and from a veterinarian’s office who is licensed in that state. 


Policy #3


The Program of Veterinary Care should require an on site visual inspection of the animals by the attending veterinarian no less than monthly. 


While the AVMA may approve the reduction of canine teeth to address human safety concerns, the purpose of the AWA is to insure the welfare of the animals which is not enhanced by such procedures.  On the contrary, such procedures put the animal at risk of severe pain caused by the exposure of the pulp cavity that may not be readily ascertained by virtue of the fact that wild animals conceal their infirmities.


Policy #5


The AWA should prohibit the exhibition of animals at auctions and other off site venues.  Due to the inherent nature of all wild animals to be stressed by loud noises, confinement, new environments and the close proximity of people, an animal auction, flea market, fair ground, school yard or shopping center parking lot exposes these animals to an unacceptable level of stress.  These situations also expose the public to an unwarranted level of risk, provide no real benefit and should be prohibited entirely.


Policy #6


Traveling acts that use big cats have been banned in other countries and at the local level in the U.S.  There is no way that any traveling display can meet the space and exercise requirements of exotic cats and no way that USDA can effectively monitor the daily requirements suggested by the AWA.  The minimal standards required in the past have never been properly enforced and are detrimental to the health and wellbeing of the animals. 


Every cat that has come to us from traveling acts has suffered from a variety of injuries as a result of the confinement including scarred hips and elbows from hitting the cage walls constantly, missing fur on the nose from incessantly rubbing their faces against the bars, chapped and bleeding feet from being kept on wood or concrete surfaces, poor muscle mass from the lack of exercise, scarred lung tissue from breathing the urine laden air, blindness from repeated photo sessions, broken teeth from biting the cage bars and a host of psychological issues from being forced into close confinement with other cats and the public.  Since there is no way to protect the welfare of these animals while they are on the road and no justifiable reason to continue the activity it should be prohibited. 


If spending money cannot be considered a factor in whether an animal is given proper medical care, then making money should not be a factor in whether or not the animal can be induced to suffer for the purpose of generating income for his owner. 


Cage space in general was not a part of your policy manual, but absolutely should be.  Some states still have no regulations governing the cage size, construction and substrates and in those places rely on USDA’s standards which are cruel beyond description.  Enough space to stand up and turn around, is not meeting the needs of any animal and especially not exotic cats who collectively are designed to roam as much as 400 square miles, leap as far at 40 feet and run at speeds of up to 70 miles per hour.   While no cage is suitable for meeting their needs, the minimums should be at least:


The family Felidae
small to medium (under 60 lbs)
large cats (over 60 lbs)
Defined as the following species:
Small Cats

  • Rusty-spotted cat (Prionailurusrubiginosus)
  • Flat-headed cat (Prionailurusplaniceps)
  • Black-footed cat (Felis nigripes)
  • Kodkod (Oncifelis guigna)
  • Oncilla/tiger cat (Leopardus tigrina)
  • Sand cat (Felis margarita)
  • Pallas’ cat (Otocolobus manul)
  • Domestic cat (Felis catus)
  • Margay (Leopardus wiedii)
  • Marbled cat (Pardofelis marmorata)
  • Geoffroy’s cat (Oncifelis geoffroyi)
  • Jaguarundi (Herpailurus yagouroundi)
  • Pampas cat (Oncifelis colocolo)
  • Leopard cat (Prionailurus bengalensis)
  • Wildcat (Felis silvestris)
  • Mountain cat (Oraeilurus jacobita)

Medium Cats  

  • Canadian lynx (Lynx Canadensis)
  • Bobcat (Lynx rufus)
  • African golden cat (Profelis aurata)
  • Spanish lynx (Lynx pardinus)
  • Fishing cat (Prionailurus viverrinus)
  • Ocelot (Leopardus pardalis)
  • Asian golden cat (Catopuma temmincki)
  • Caracal (Caracal caracal)
  • Jungle cat (Felis chaus)
  • Serval (Leptailurus serval)
  • Eurasian lynx (Lynx lynx)

Large cats (weighing more than 60 lbs.)  

  • Lion (Panthera leo)
  • Tiger (P. tigris)
  • Leopard (P. pardalis)
  • Snow leopard (Uncia uncial)
  • Jaguar (P. onca)
  • Cheetah (Acinonyx jubatus)
  • Clouded leopard (Neofelis nebulosa)
  • Puma (Puma concolor)  

And all subspecies and hybrids thereof
Species Needs
In the wild, all species of small cats are more or less solitary, i.e. intolerant towards adults of the same sex, and exhibit a spatially and temporally dispersed social system.
With one exception, (lions) large felids are solitary carnivores functioning at or near the top of their trophic level.
Felids are predators relying on cover for survival.
Leopard, (P. pardalis); Snow leopard, (Uncia uncial); Jaguar, (P. onca); Cheetah, (Acinonyx jubatus); Clouded leopard, (Neofelis nebulosa); Puma, (Puma concolor) are more secretive animals when compared to lions and tigers and require ample areas of cover.
Felids are inquisitive, exploratory and in the wild are particularly active at night, dawn and dusk.
Felids are primarily carnivorous.
Felids are frequently avid climbers and, if clawed, need trees or wood to shed and sharpen their claws.

Enclosure Requirements


Enclosures for felids shall primarily consist of a mix of natural substrates (e.g., soil, sand, grass, natural rock) that provide good drainage and have an area(s) that can be readily cleaned and sanitized for feeding and resting.

Size & Complexity

  • Enclosures shall provide sufficient mix of cover such as brush, tall grasses, trees, den areas, elevated areas and opportunities to climb. Enclosures shall provide ledges or perches for sleeping and resting.
  • Enclosure size for one or two small animals shall be 400 square feet at a minimum. Each additional animal requires an increase of 25% of the original floor space, (ie. for two animals, the minimum space is 500 square feet).
  • Enclosure size for one or two medium animals should be 600 square feet at a minimum. Each additional animal requires an increase of 25% of the original floor space.
  • Enclosure size for one large animal weighing over 60 lbs., should be 1200 square feet at a minimum. Each additional animal requires an increase of 25% of the original floor space.
  • Of equal importance to enclosure size is the complexity and variability of the enclosure.
  • Enclosures shall be designed to allow terrestrial species the ability to utilize the vertical component of the enclosure by providing aerial pathways.

Enclosure Construction & Elements

  • Most felids are adept climbers and can easily scale a chain link fence and jump from trees and branches to clear a fence. Enclosures shall be designed and constructed to securely contain the species contained therein.
  • Some felids may dig underneath a fence line so for these cats that are individually prone to digging the enclosure perimeters shall have either a concrete footing, horizontal protective mat around the entire enclosure or chain link fence that is buried at a depth sufficient to prevent escape given the composition of the natural substrate.
  • Dens shall be provided and shall be dry, and of sufficient size to make the animals feel secure. In enclosures with multiple animals, there shall be one den space for each animal in the enclosure.
  • Some felids enjoy swimming, and pools of an appropriate size and depth should be incorporated into outdoor enclosures where possible.
  • Arboreal cats as defined herein, shall have places to climb in order to meet their spatial needs and places to lounge above the terrain to meet their emotional needs.


  • The aggressive nature of most felids, and their physical strength and capabilities, demand that care-givers take extreme care when designing enclosures for any felid species, regardless of their size, to reduce the risk of escape or reaching through enclosure fencing.
  • For small or medium felids, enclosure fencing shall be least 8 ft. high with the top protected by either electric wire or a 45-degree 2 ft. inward-facing overhang. Additional local and state requirements may apply.
  • For large felids, enclosure walls shall either be 12 feet high and be some combination of vertical wall with at least a 2 foot back-arm at a 45 degree angle, or be provided with complete tops and at least 10 feet high, or double rows of hot wire will be sufficient for lions and tigers who are not avid climbers. The cage shall be constructed of no less than 9 gauge wire for large felids and no less than 12 gauge wire for small to medium felids.
  • As many felids, especially tigers and jaguars, enjoy water, water moats shall not be used to contain felids.
  • Shift or secondary holding areas shall be provided to allow for safe movement of animals from their primary enclosure into a secure area for cleaning, feeding, maintenance, medical and other necessary procedures.
  • There shall be one holding area for each cat. For small cats, each shift area shall be no less than 2 feet high with a minimum of 4 square feet of floor space. For medium cats, each shift area shall be no less than 2 feet high with a minimum of 6 square feet of floor space. For large cats each shift area shall be no less than 3 feet by 6 feet. Holding or shift areas shall only be used for temporary confinement of animals and for periods not to exceed four hours unless under the direct supervision of a veterinarian for medical purposes.
  • At a minimum, each enclosure shall be equipped with a double door system to prevent escape and the cages should be kept locked. No cages shall be adjoining unless adequate provisions have been made to keep the animals from reaching through or getting a tail or ear into the adjoining cage to prevent injury.


  • Natural substrates shall be cleaned and maintained according to the Animal Waste Removal and Sanitation Plan.


  • Some tropical species of small cats as well as temperate ones can tolerate a fairly wide range of temperatures, but it is necessary to acclimate them slowly to lower temperature ranges.
  • Although large felids may originate from all manner of climates, most are tolerant of wide temperature extremes, at least during the daylight hours. When acclimated, most adults require only unheated shelter at night.
  • Clouded leopards are more sensitive to cold temperatures and shall be protected from cold temperatures.
  • If temperature extremes exceed those of a felid’s native habitat, then shelters shall be provided with space heaters for use in winters and cooling systems for summer to bring the ambient temperature into accordance with the cat’s native habitat. Heaters and cooling systems shall be properly designed and situated to prevent destruction by the felid.


  • Felid diets shall be based upon commercially available beef or horse-based diets or custom-made diets which contain all necessary vitamin and minerals. Custom-made diets shall be reviewed by the attending veterinarian and/or veterinary nutritionist.
  • Whole animal carcasses (rodents, rabbits, or fowl) may be substituted as feed on occasion to vary the diet and shall be limited to fresh or thawed carcasses, the remains of which shall be removed prior to deterioration or spoilage. All food shall be handled according to the guidelines set forth in the USDA Handbook.
  • Diets containing high percentages of all muscle and organ meat or high percentages of fowl by-products such as chicken or turkey necks are nutritionally unbalanced and shall be avoided due to inadequate levels of vitamins and minerals.
  • Communal feeding is discouraged for most felid species to prevent aggression or other dominant behavior among animals. If communal feeding does occur, weights and conditions of all animals shall be closely monitored.
  • Large felids may be fasted one day per week. Felids weighing less than 15 lbs. shall not be fasted.
  • Bones, especially those from joints or knuckles, should be given at least once a week.
  • Feeding large felids carcasses obtained from road kills or donations is not recommended because of the potential for contamination; and use of feed animals selected from such sources shall be inspected by the attending veterinarian to insure they are free of disease.
  • Some felid species routinely defecate in the water. Raising the primary drinking water bowl above the tail of the cat may help prevent contamination of water source. The water bowls should be cleaned daily and kept full at all times. The bowls must be species appropriate in size and construction so that the cat doesn’t chew up and digest a plastic bowl. Cool fresh water shall be available for the cat to drink at all times.
  • Milk substitutes used to hand rear infants shall be specifically formulated for felids and approved by the veterinary staff. Milk replacers shall contain appropriate levels of vitamins, minerals and other ingredients to prevent developmental and other medical problems. Kittens and cubs should never be born in a sanctuary, but if they are, every attempt should be made for the mother to raise her own offspring. Proof of the cat’s inability to raise her own offspring must be in writing by the attending veterinarian.


Social, Psychological, Physical and Behavioral Well-Being  

  • Where a microchip transponder is used as a means of identification, it shall be placed at the base of the left ear.
  • The unique veterinary concerns for felids shall be addressed by the veterinarian and shall include:
  • Preventative heartworm medication shall be given to all felids housed in areas where this parasite is prevalent, and an occult heartworm test performed periodically.
  • Periodic (at least yearly) fecal examinations shall be required to check for parasite infestation, and appropriate parasite therapy instituted as necessary.
  • Unless recommended differently by the attending veterinarian, all felids shall receive annual prophylactic vaccinations for protection against feline distemper (panleukopenia), rhinotracheitis, and calicivirus (FVRCP), annually. Only Killed Virus (KV) products shall be used. Felids shall be vaccinated against rabies annually using KV products. Felids are also susceptible to non-specific diseases such as tuberculosis and should tested when practical
  • Kittens shall be vaccinated with KV FVRCP (fel-o-vax) vaccine at 6-8 weeks, and receive a series of four immunizations every three weeks as well as when 6 and 12 months of age. A killed rabies vaccine shall be given at 4 months of age and annually thereafter.
  • Fleas can be a problem in some areas and shall be controlled by spraying the enclosure with an approved commercial insecticide. Topical insecticides as approved by the attending veterinarian as safe for feline species may also be used if necessary.
  • Some felids may benefit from companionship with other felids, even if this is not natural for them in the wild. Newly introduced animals may fight to establish the hierarchy. All introductions must be done carefully and animals must be closely monitored during the introduction phase.
  • Each enclosure shall have an accessible device to provide physical stimulation or manipulation compatible with the species. Such device shall be non injurious, and may include, but is not limited to, boxes, balls, bones, barrels, drums, rawhide, pools, etc.
  • Felids are intelligent animals and easily bored. Enrichment that is appropriate to the species shall be provided no less than weekly in a form that is different from their daily use of toys and cage furnishings.


  • Large felids shall not be handled except for medical purposes.


  • New felids arriving at the sanctuary shall be quarantined for a minimum of 30 days.
  • Footbaths shall be used prior to entering and exiting all quarantine felid enclosures, or areas containing quarantined animals. Each shall be filled with a disinfectant and its use strictly adhered to by all personnel.
  • Upon arrival, all felids shall undergo quarantine according to protocol as established by the attending veterinarian. All felids shall be tested for Feline Immunodeficiency Virus (FIV), Feline Infectious Peritonitis (FIP), Feline Leukemia Virus (FeLV), and Toxoplasmosis prior to placing the animal with or near other felids.


Policy #8


USDA should be required to seize and place animals when they have suspended or revoked a license and the former licensee continues operations in violation of the order.  There is no reason for anyone to subject themselves to licensing under the current situation where there is little or no enforcement or penalty for acting outside of the law.  Fines against the indigent are of no value.  Big Cat Rescue is currently in the process of rescuing 6 lions and tigers who were still being used for a tiger-tamer camp several years after USDA suspended and then revoked the license of Diana McCourt.  She was able to continue endangering the animals and the public with flagrant disregard for USDA’s ruling because there was no disincentive to her.  It wasn’t until the county stepped in and seized the big cats that any relief could be provided to the animals. 


Policy #11-#20


All research facilities should be required to post their activities regarding regulated animals on the Internet in a manner that is easily accessed by the public.  This would end much of the pain and suffering that animals endure due to the duplicative procedures being carried out behind closed doors.  At the time that the AWA was written we did not have the scientific tools we have today which are far more effective and do not require the use of animals.  The very term “Animal Welfare” runs contrary to anything being done to animals in research facilities in the name of science.  By revealing these activities to the public you would enhance collaborative efforts for the common good.  The social pressure to find alternatives could take us from the dark ages to an age of discovery for cures that continue to elude us because we keep doing the same thing over and over expecting a different result.  Einstein defined that as insanity. 


Policy #25


No animal that dies of unknown causes (regardless of the suspected cause) should be fed to a captive feline.  Whether the prey animal died in the field, was so sick it was killed, was found alongside the road or was purported to be killed by a hunter, there is no way to ensure the quality of the dead animal as food for a captive cat.  Roadkill and animals killed by hunters could also have been poisoned and there is no way to ensure that the carcass has not been contaminated or left exposed long enough to harbor an excessive bacteria count or worm infestation. 


While the policy of requiring that cats not be starved more than 2 days is a good one, it is impossible to regulate unless there is a quantifiable formula such as how many pounds of food is consumed in a day per animal vs receipts for the appropriate amount of food to have been available to the cats.  When an inspector only comes along once a year or so, there is no other way they can insure that the cats have not gone through long periods of starvation. 



Another policy that needs to be added is that of handling big cats and their babies.  The primary reason for the over abundance of big cats in private hands is that they are bred for photo ops, petting sessions, public appearances and hands on training camps.  As long as there is any window of time in which the public may have contact with baby big cats, there will be those who will breed for that market and discard or warehouse the animals when they outgrow the time frame or weight requirement.


There is no benefit to the animal and no legitimate benefit to society to allow contact between exotic cats and the public.  To allow photo sessions, even with the restriction of non contact, will only perpetuate the problem as there will never be enough USDA inspectors to be at every photo shoot for the entirety of the session to enforce the rule.  Prohibiting these practices will protect the public and will prevent the unscrupulous breeding of big cats.  There is a federal bill pending now, called Haley’s Act, HR 1947 that would ban this activity and requires that USDA not issue any new permits until they promulgate the rules to enforce this new law.  USDA should be proactive and ban this practice immediately.  In order to keep licensees from exploiting a loop hole in the rule, the public should be defined as anyone other than the licensee or their full time, paid employees for the purpose of this rule. 



Freedom of Information.  USDA is running three years behind in answering freedom of information act requests and that effectively inhibits any real ability to garner information necessary to protect animals and the public.  All licensee records should be available via the Internet to any member of the public at all times.  This transparency alone would greatly enhance USDA’s ability to police licensees because public scrutiny is the only kind that gets results.  We live in a digital age where documents can be scanned and filed for public record in a matter of seconds.  If information is available for a fee it is public record and if it is public record it should be available to the public in a timely manner that does not require exhaustive efforts on the part of the public to cajole the government into providing the information.  A little effort at the front end of the process will save countless man power hours in gathering and providing information by the USDA on the back end. 



Last, but not least, there should be a requirement that all exotic animals be regulated by USDA whether they are officially considered an exhibit or not.  In twenty years of experience in the exotic animal industry I have never seen a case where a person purchased an exotic cat for any truly non commercial purpose.  Whether the animal is held for the purpose of skinning for her fur, which would then be sold (commerce), or as a pet which is always bought to show off to others (exhibition) or held in a sanctuary (non profits are owned by the public by definition) the animals are always held captive for some commercial purpose despite heated debate to the contrary. 


The captive animal doesn’t discern the difference between being kept in a cage as a pet, a product, a rescue or an exhibit and the Animal Welfare Act shouldn’t exclude protection based on those uses either. 



For the cats,


Carole Baskin, CEO of Big Cat Rescue

an Educational Sanctuary home

to more than 100 big cats

12802 Easy Street Tampa, FL  33625

813.493.4564 fax 885.4457

http://www.BigCatRescue.org    MakeADifference@BigCatRescue.org


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