USDA to require shift cages for big cats
May 8, 2006
Docket No. APHIS- 2005-0118
Regulatory Analysis and Development, PPD, APHIS,
Station 3A- 03.8, 4700 River Road Unit 118,
Riverdale, MD 20737-1238
Re: Docket No. APHIS- 2005-0118,
Big Cat Rescue is the world’s largest accredited rescue facility that is entirely devoted to exotic cats. We have 40,000 supporters around the globe and are united in our following request. We are relieved to see USDA taking a proactive step to protecting both the public and the animals by requiring that ALL transport be done using a proper shift cage and properly trained personnel.
Leopards were not listed as a big cat and are not only larger than most pumas and cheetahs, but are the most dangerous of all of the cat species due to their much higher level of intelligence. In virtually all other realms the leopard is considered a big cat and should be added to your list.
In addition to adding leopards to your list, we would implore you to add ALL non domestic felids for the following reasons:
Small wildcats are even more likely to slip past a handler because the handlers often underestimate the determination of the cat and the damage that a released wild cat can cause. While a released bobcat is unlikely to kill an adult, they can easily kill a child given that they often hunt and kill adult, fully tusked wild boar with relative ease. Most of the captive wildcats are larger than the native cats in their area and if they escaped could wipe out native populations of existing cat species, and their prey base as well. An even more dangerous threat is that of the released wildcats spreading disease in native populations and hybridizing with native populations creating a host for disease and genetic mutation that we have no science to understand or control. Servals, Caracals, Jungle Cats, Fishing Cats, Siberian and Canada Lynx and hybrids of all of the above are all larger than bobcats in most cases and thus more dangerous still.
There is NO reason not to treat ALL wild cats as potentially dangerous and take precautions to prevent their escape.
Requiring shift cages for all transport of all cat species between their main enclosures and their temporary enclosures eliminates the two things that cause people to foolishly breed and/or buy these animals. The two main attractions in having a wild cat are to show off by walking the animal on a leash and to chain the animal down to use them for photo or petting sessions. Neither of these activities does anything to promote an understanding of the plight these cats face in the wild and thus does nothing for conservation; which is almost always the excuse used for this behavior.
When dealing with any sort of non domestic cat it is imperative that all enclosures have a safety entrance area in addition to the use of shift cages. We have enclosed photos and descriptions of the shift cages, lock out boxes, external handling of interior doors and safety entrances and how we utilize them at Big Cat Rescue and welcome the use of these protocols by any facility housing exotic cats.
In summary there is never an opportunity for a cat to get out a door because there is always at least one more back up door between the cat and outside world. Having these systems is only part of the solution. We maintain written protocols on how the systems are to be used and training in using them and then further restriction to just a handful of our most highly qualified staff who may actually enter a cage or shift a cat. A USDA agent should be able to read the protocols of each facility upon request and compare that to the knowledge of the designated keepers to check for implementation.
One last suggestion would be necessary for this rule to be followed in the absence of direct supervision on a daily basis by USDA and that is mandatory microchipping. If every animal were required to be microchipped and registered with USDA along with a photo and complete description then there would be no doubt when a cougar walks into town and starts hanging out at the local school that the animal (when caught) could be proven to have belonged to someone who is now responsible for the cost of capture and damage done. If people had to be responsible for the animals they breed, sell and own there would be a lot more time and effort put into making sure that animal did not escape and cause harm.
The best rules in the world don’t work if you don’t have the money to implement them and USDA is woefully understaffed and under funded so the only way these rules will be of any effect is if the animal owner can be made accountable and thus self policing.
For the cats,
Carole Baskin, Founder
[Federal Register: April 28, 2006 (Volume 71, Number 82)][Proposed Rules] [Page 25100-25102]From the Federal Register Online via GPO Access [wais.access.gpo.gov][DOCID:fr28ap06-18] Proposed Rules Federal RegisterThis section of the FEDERAL REGISTER contains notices to the public of the proposed issuance of rules and regulations. The purpose of these notices is to give interested persons an opportunity to participate in the rule making prior to the adoption of the final rules. [[Page 25100]] DEPARTMENT OF AGRICULTURE Animal and Plant Health Inspection Service 9 CFR Part 2 [Docket No. APHIS-2005-0118] Shift Cage Requirements AGENCY: Animal and Plant Health Inspection Service, USDA. ACTION: Proposed rule.SUMMARY: We are proposing to amend the Animal Welfare Act regulations concerning the handling of animals to require that shift cages be used for handling certain species. One of the largest risk factors for animal escape and employee and animal injury occurs when it is necessary to move, or shift, certain animals between enclosures. Requiring shift cages for certain species would mitigate the risk of injuries to people and animals as well as ensure safe transport of animals between enclosures and exhibits. DATES: We will consider all comments that we receive on or before June 27, 2006. ADDRESSES: You may submit comments by either of the following methods: Federal eRulemaking Portal: Go to =
gov and, in the lower “Search Regulations and Federal Actions” box, select “Animal and Plant Health Inspection Service” from the agency drop-down menu, then click on “Submit.” In the Docket ID column, select APHIS-2005-0118 to submit or view public comments and to view supporting and related materials available electronically. Information on using Regulations.gov, including instructions for accessing documents, submitting comments, and viewing the docket after the close of the comment period, is available through the site’s “User Tips” link. Postal Mail/Commercial Delivery: Please send four copies of your comment (an original and three copies) to Docket No. APHIS-2005-0118, Regulatory Analysis and Development, PPD, APHIS, Station 3A-03.8, 4700 River Road Unit 118, Riverdale, MD 20737-1238. Please state that your comment refers to Docket No. APHIS-2005-0118. Reading Room: You may read any comments that we receive on this docket in our reading room. The reading room is located in room 1141 of the USDA South Building, 14th Street and Independence Avenue, SW., Washington, DC. Normal reading room hours are 8 a.m. to 4:30 p.m., Monday through Friday, except holidays. To be sure someone is there to help you, please call (202) 690-2817 before coming. Other Information: Additional information about APHIS and its programs is available on the Internet at =
usda.gov. FOR FURTHER INFORMATION CONTACT: Dr. Barbara Kohn, Senior Staff Veterinarian, Animal Care, APHIS, 4700 River Road Unit 84, Riverdale, MD 20737-1234; (301) 734-7833. SUPPLEMENTARY INFORMATION: Background The Animal Welfare Act (the Act, 7 U.S.C. 2131 et seq.) authorizes the Secretary of Agriculture to promulgate standards and other requirements governing the humane handling, care, treatment, and transportation of certain animals by dealers, research facilities, exhibitors, carriers, and intermediate handlers. The Secretary of Agriculture has delegated the responsibility of enforcing the Act to the Administrator of the Animal and Plant Health Inspection Service (APHIS). The regulations established under the Act are contained in title 9 of the Code of Federal Regulations (9 CFR), chapter I, subchapter A, parts 1, 2, and 3. Regulations regarding handling of animals are found in 9 CFR part 2. Section 2.131 contains provisions for the humane handling of animals. In Sec. 2.131, paragraph (b)(1) states that handling of all animals must be done as expeditiously and carefully as possible in a manner that does not cause trauma, overheating, excessive cooling, behavioral stress, physical harm, or unnecessary discomfort. One of the largest risk factors for animal escape and employee and animal injury occurs when it is necessary to move, or shift, certain animals between enclosures. An increasing number of reports of human and animal injuries that have occurred during the movement of certain animals between enclosures have led APHIS to focus on ways to mitigate such risks and promote safer conditions for animals, their handlers, and the public. Therefore, we are proposing to amend the regulations to add specific requirements for the handling of certain animals during their movement between enclosures. Specifically, we propose to add a new paragraph (f) in Sec. 2.131 that would require the use of shift cages for moving and transporting potentially dangerous animals, such as big cats (lions, tigers, pumas, jaguars, and cheetahs); all species of bears; great apes (gorillas, chimpanzees, orangutans) and other nonhuman primates; and wild or exotic canids. While shift cages may vary from facility to facility, the shift cages would have to work in such a manner as to safely and securely enclose the animal. Shift cages can be permanent, such as the connection between two enclosures that can be shut at both ends as can be found in zoos, or temporary, such as those used to transport animals. In either case, we would require that shift cages attach or be attachable to all enclosures or holding pens, cages, or secured areas used to hold and/or transport potentially dangerous animals in such a way that the animal cannot get through any gaps between the shift cage and the enclosure. In addition, the shift cages would have to allow handlers access to the animal’s primary enclosure without posing a threat to the handler. Proper maintenance of shift cages is vital in ensuring the safe handling of animals and the protection of their handlers. Equipment may rust, malfunction, incur damage, or otherwise compromise the security of the enclosure. Left unrepaired, such damage may allow an animal to escape or result in injury to an animal or handler. Therefore, we would also require that the shift cage be structurally sound and maintained in good repair to protect the animals from injury and to contain the animals. Improper handling of shift cages may result in the escape of a potentially dangerous animal or injury to the animal, handler, or a member of the public. For this reason, it is important that all personnel involved in moving or transporting potentially dangerous [[Page 25101]] animals understand how to correctly operate all components of the facility’s shift cage or alternative system equipment. We would require that all personnel whose duties include a role in the movement or transportation of potentially dangerous animals be trained in the proper use of the equipment, and that written protocols for the safe transfer of animals be established by the facility. Most accredited or well-run facilities already have systems in place for the movement of animals between enclosures. As such, this proposed rule would also allow for facilities to employ other methods as alternatives to shift cages, provided that those alternative methods afford the same degree of assurance against animal escapes and for the protection of employees and the public. If a facility wishes to employ an alternative measure, a description of that method would have to be submitted in writing to the appropriate Animal Care regional office and would have to receive written approval before the method could be used as an alternative.
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
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