Animal Welfare Inspection Guide

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employer.

Revised November 2021
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Contents

Tip: Depending on your application settings, you may have to use CTRL-click to use hyperlinks.

Introduction 1-1

1.1. Purpose 1-2

1.2. Disclaimer 1-3

1.3. Meaning of Must, Should, and May 1-4

1.4. Meaning of Bulleted and Numbered Lists 1-5

1.5. Using the Inspection Guide 1-6

1.6. Inspection Guide Updates 1-7

Required Inspection Procedures 2-1

2.1. Required Inspection Procedures 2-3

2.2. Safety 2-4

2.3. Inspection Steps 2-5

2.4. Inspection Findings 2-6

2.5. Inspection Photographs 2-14

2.6. Inspection Inventory 2-16

2.7. Exit Interview 2-20

2.8. Delivery of the Inspection Report 2-21

2.9. ACI Team Inspection with a VMO after a Veterinary Care Direct 2-22

2.10. Risk Based Inspection System (RBIS) 2-23

2.11. Deciding Not to Conduct an Inspection 2-24

2.12. Attempted Inspection 2-25

2.13. Prelicense Inspection 2-26

2.14. Refusal of Inspection 2-27

2.15. Interference 2-28

2.16. Correcting, Rescinding, and Amending an Inspection Report and/or 

Inventory 2-29

2.17. Inspection Report and Teachable Moments Review 2-30

General Inspection Procedures 3-1

3.1. Preparing for the Inspection 3-3

3.2. Conducting the Inspection 3-4

3.3. Completing the Inspection Report 3-21

3.4. Safety and Ethics Issues 3-38

Specific Types of Inspections 4-1

4.1. Airport Inspection 4-4

4.2. Animal Rides 4-6

4.3. Attempted Inspections 4-8

4.4. Auction Market Inspection 4-16

4.5. Barrier Facility Inspection 4-19

4.6. Change in Class of License Inspection 4-21

4.7. Complaint Inspection 4-23

4.8. Courtesy Visits 4-25
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4.9. Dead Animal/Parts or Serum/Blood Dealer Inspection 4-29

4.10. Dogs and Cats in Residence Inspection 4-31

4.11. Domestic Hoofstock Inspection 4-33

4.12. Drive-through Zoo/Park Inspection 4-34

4.13. Lion and Tiger Enclosure Inspection 4-41

4.14. Marine Mammal Facility Inspections 4-43

4.15. New Site Approval Inspection 4-51

4.16. Pet Store Inspection 4-53

4.17. Petting Zoo Inspection 4-55

4.18. Photo Shoot Inspection 4-59

4.19. Prelicense Inspection Process 4-62

4.20. Search Inspection 4-72

4.21. Traveling Exhibitor Inspection 4-78

4.22. Wild/Exotic Animal Auction Inspection 4-89

Record-Keeping for Licensees 5-1

5.1. Records 5-2

Veterinary Care Requirements for Licensees 6-1

6.1. Attending Veterinarian 6-2

6.2. Written Program of Veterinary Care 6-7

6.3. Records 6-10

6.4. Inspection Guidance 6-14

6.5. Documentation of Veterinary Care NCIs 6-28

Research Facility Inspection 7-1

7.1. IACUC Review Information 7-3

7.2. Protocol Review Information 7-12

7.3. Veterinary Care Requirements for Dogs 7-24

7.4. Contracted Research or Projects that Involve Multiple Registrants 7-27

7.5. Records 7-29

7.6. Guidance for Veterinary Schools and Veterinary Technician Programs 

(VTP) for the Inspector 7-36

7.7. Inactive Research Facility or Research Facility with No Activity for 

Two Years Inspection 7-38

7.8. Holding Period 7-40

7.9. Research Facility Protocol Selection Worksheet 7-41

Appendices 1

Forms and Worksheets A-1

Official APHIS Forms A-2

Amended Inspection Report Letter A-3

Attempted Inspection Checklist A-4

Attempted Inspection Leave-Behind Flyer A-5

Attempted Inspection Letter and Enclosure A-6

Attempted Inspection – Script Following an Attempted Inspection A-8

Complaint Worksheet A-12
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Environmental Enrichment Plan Inspection Checklist A-13

Facility Contact Worksheet A-15

Inspection Report Review Checklist A-16

Search for Unlicensed Activity Worksheet A-18

Teachable Moments Review Checklist A-19

Unsatisfactory Optimal Hours Response Letter A-21

General Information B-1

Dangerous, Potentially Dangerous, and Special License Animals B-2

Options for Identification of Dogs and Cats B-3

Personally Identifiable Information (PII) Examples B-4

State and Territory Identification Codes B-5

NCI/Direct/Critical Noncompliance Examples C-1

Examples for Dogs and Cats C-2

Examples for Other Animals C-13

Equipment and Supplies D-1

Body Condition and Size Charts E-1

Cat E-2

Cougar E-3

Dog E-4

Elephant E-5

Leopard E-6

Lion E-7

Tiger E-8

Tiger cub size information E-9

Acronyms F-1

Index 1
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Introduction

Contents

1.1. Purpose 1-2

1.2. Disclaimer 1-3

1.3. Meaning of Must, Should, and May 1-4

1.4. Meaning of Bulleted and Numbered Lists 1-5

1.5. Using the Inspection Guide 1-6

Questions or Concerns with the Inspection Guide 1-6

1.6. Inspection Guide Updates 1-7
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1.1. Purpose

The purpose of the Animal Welfare Inspection Guide is to provide an aid for 

APHIS Animal Care personnel when inspecting USDA licensed and registered 

facilities.

The Inspection Guide is not a Regulation or Standard and does not rise to the 

level of policy. It serves as a tool to improve the quality and uniformity of 

inspections, documentation, and administration of the Animal Care Program.

The Inspection Guide is designed to facilitate the decision-making process. It

cannot, and is not intended to, replace the inspector’s professional judgment.

The Inspection Guide summarizes current regulatory and procedural criteria for 

USDA licensed/registered facilities and provides examples of inspection 

processes for verifying compliance. It does not add to, delete from, or change 

current Regulations or Standards.
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1.2. Disclaimer

The Animal Welfare Inspection Guide is intended to be a reference document to 

assist the inspector. The Inspection Guide does not supersede the Animal 

Welfare Act (AWA), the AWA Regulations and Standards, AC policies and other 

guidance, the Required Inspection Procedures, standard procedures, or the 

inspector’s professional judgment. All inspection decisions must be justified by 

applicable sections of the AWA and/or the AWA Regulations and Standards.
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1.3. Meaning of Must, Should, and May

The words “must,” “should,” and “may” are used throughout the Guide as 

follows:

• Must is used when the referenced action is required by an Animal Care 

procedure or by the 9 CFR Regulations/Standards

• Should is used when the referenced action(s) is:

o Directed by Animal Care Management:

- Strongly recommended, but not specifically required by an Animal 

Care procedure, or

- Strongly recommended, but not specifically required by the Title 9 

Code of Federal Regulations (CFR) Regulations/Standards

• May is used when the referenced action(s) is optional
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1.4. Meaning of Bulleted and Numbered Lists

Bulleted lists indicate that there is no particular order to follow.

Numbered lists mean that each step is meant to be done sequentially.
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1.5. Using the Inspection Guide

Review the contents of the Inspection Guide to get a feel for the scope of 

covered material. Use the Table of Contents in each chapter (mini TOC) to find 

the needed information. If the Table of Contents is not specific enough, turn to 

the index to find the topic and corresponding page number.

Questions or Concerns with the Inspection Guide

If you have questions or concerns about the information in the Inspection Guide, 

you should contact your Supervisory Animal Care Specialist (SACS).
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1.6. Inspection Guide Updates

The Animal Care (AC) Unit issues and maintains this Inspection Guide 

electronically on the AC Website. The Inspection Guide on the Animal Care 

Website has the most up-to- date information.

Notification of revisions to the Inspection Guide are distributed via the APHIS 

Stakeholder Registry to anyone who has subscribed to receive Animal Care 

program updates. To subscribe to updates, register here.

Each update contains the following information:

• Link to access and download the online Inspection Guide

• List of the revised page numbers

• Purpose of the revision
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Required Inspection Procedures

Contents

2.1. Required Inspection Procedures 2-3

General Requirements 2-3

2.2. Safety 2-4

Inspector Safety 2-4

Biosafety 2-4

2.3. Inspection Steps 2-5

2.4. Inspection Findings 2-6

No Noncompliant Items (NCIs) Identified 2-6

Teachable Moments 2-6

New NCIs Cited 2-8

Repeat NCI 2-9

Recurring/Chronic NCI 2-9

“Critical” NCI Identified 2-10

“Direct” NCI Identified 2-11

Correction Date Guidelines 2-11

Direct NCI on a New Site Approval Inspection 2-12

“Veterinary Care Direct” NCI Identified 2-12

Handwritten or “Word” Inspection Reports 2-12

Airport Inspections 2-13

2.5. Inspection Photographs 2-14

Photographs/Videos Documenting Noncompliances 2-14

Showing Photos during Exit Interview 2-15

Licensee/Registrant Requesting Photographs 2-15

2.6. Inspection Inventory 2-16

Before the Inspection 2-16

During the Inspection 2-16

After the Inspection 2-18

2.7. Exit Interview 2-20

2.8. Delivery of the Inspection Report 2-21

Signature on the Inspection Report 2-21

2.9. ACI Team Inspection with a VMO after a Veterinary Care Direct 2-22

2.10. Risk Based Inspection System (RBIS) 2-23

2.11. Deciding Not to Conduct an Inspection 2-24

2.12. Attempted Inspection 2-25

2.13. Prelicense Inspection 2-26

2.14. Refusal of Inspection 2-27

2.15. Interference 2-28

2.16. Correcting, Rescinding, and Amending an Inspection Report and/or 

Inventory 2-29
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Correcting an Inspection Report and/or Inventory 2-29

Rescinding and Amending an Inspection Report and/or 

Inventory 2-29

2.17. Inspection Report and Teachable Moments Review 2-30

Inspection Report Review 2-30

Teachable Moment Review 2-30

DISCLAIMER

The Animal Welfare Inspection Guide is intended to be a reference document to assist the 

inspector. The Inspection Guide does not supersede the Animal Welfare Act (AWA), the AWA 

Regulations and Standards, AC policies and other guidance, the Required Inspection 

Procedures, standard procedures, or the inspector’s professional judgment. All inspection 

decisions must be justified by applicable sections of the AWA and/or the AWA Regulations 

and Standards.
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2.1. Required Inspection Procedures

The procedures set forth in this Chapter are procedures that must be followed 

by the inspector when conducting an inspection. If you, the inspector, are 

unsure of a required procedure, contact your Supervisory Animal Care Specialist 

(SACS). For more detailed general inspection procedures, refer to Chapter 3.

General Requirements

When conducting an inspection, the inspector must follow the general 

requirements listed below:

• Do not enter facilities with locked gates and/or “No Trespassing” signs unless 

you obtain prior approval from the facility

• If you arrive at the facility and determine that it is not appropriate to conduct 

an inspection, refer to Deciding Not to Conduct an Inspection

• If you do not find anyone at the facility, follow the Attempted Inspection

procedure to complete an Attempted Inspection

• Prior to notifying the facility of your presence, inspectors may observe and 

record findings without being accompanied by a facility representative at 

facilities that are open to the public. Identify yourself to the licensee 

immediately after the observation. Before documenting findings on an 

Inspection Report, the inspector must discuss the findings with a facility 

representative.

• You must be accompanied by the licensee, registrant, or the facility’s 

designated representative (who must be at least 18 years of age)

• Conduct a complete exit interview
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2.2. Safety

Inspector Safety

If you feel you are in imminent danger, promptly leave the area.

The licensee/registrant/applicant is responsible for ensuring the safety of the 

inspector during the inspection. If you feel at all unsafe, ask the licensee/ 

registrant/applicant to correct the situation. If the licensee/registrant/applicant 

does anything you feel is unsafe, state that you will leave the facility immediately 

unless the situation is corrected. [2.4]

Biosafety

In all situations, follow the facility’s visitor biosafety procedures, and/or put on 

recommended protective clothing, gear, and/or boots.

Inspectors must:

• Wear disposable shoe covers during dog kennel inspections

• Wear disposable gloves if it is necessary to touch an animal at all facilities

• Change gloves between animals or between enclosures

For more specific biosafety procedures, see Biosafety Measures in Chapter 3 and 

the AC Safety & Health Manual.
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2.3. Inspection Steps

Basic steps to follow in conducting a Routine Inspection of a facility include, but 

are not limited to:

• Review previous Inspection Reports with special attention to Veterinary Care 

and Direct Noncompliant Items (NCIs) and review previous Teachable 

Moments and animal inventories

• Review Customer content in eFile, including but not limited to, status of 

license, address, comment section and RBIS

• Inspect the animals, premises, building(s), enclosures, equipment, and 

transportation vehicles/equipment for all pertinent requirements of the 

Regulations and Standards

• Ensure that all primary enclosures can safely contain the animals

• Review the facility’s program of veterinary care, husbandry practices, 

required records and, when appropriate, the “Exercise Plan for Dogs”, and 

the plan for environmental enhancement for nonhuman primates (Optional 

APHIS Form 7050 may be used.)

• When possible, observe the animal handling techniques of facility personnel

[2.131]

• Consider problems that may occur at other times of the year

NOTICE

Inspection steps are covered in detail in General Inspection Procedures in 

Chapter 3.
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2.4. Inspection Findings

Document inspection findings in the narrative section of the Inspection Report. 

Do not type any personal identifiable information (PII) or confidential or 

proprietary business information in the narrative of any Inspection Report, 

including addresses and phone numbers.

No Noncompliant Items (NCIs) Identified

If all items are in compliance, eFile will put the following statement on the 

Inspection Report: “No noncompliant items identified during this inspection.”

If there are only TMs and no citations on the Inspection Report, eFile will put the 

following statement on the Inspection Report: “No noncompliant items 

documented on this inspection report.”

For inspections in response to an incident or complaint, further review may be 

needed to determine compliance. If you are uncertain whether a 

noncompliance was involved, do not write an Inspection Report. Discuss the 

findings with your SACS to determine what action is needed.

For Site Approval Inspections, eFile will put the following statement on the 

Inspection Report: “No noncompliant items identified during this inspection. 

This site is now approved for regulated activity.”

Teachable Moments

Teachable Moments (TM) are minor NCIs identified during an inspection that 

meet certain criteria and are not cited on an Inspection Report. Cite any 

noncompliance that is adversely impacting the health or well-being of an animal 

(for example: lack of adequate water, food, ventilation, or anything causing pain 

or distress) on the Inspection Report. If you identify an area that is not a 

noncompliant item, but you are concerned that it may become one in the future, 

discuss the concern with the licensee/registrant, but do not list it as a teachable 

moment.

The inspector should decide if each issue observed on an inspection is (in this 

order):

1. In compliance, but an area of concern or discussion topic that is not a 

teachable moment or an NCI. This could be a talking point during the exit 

discussion.

2. A Teachable Moment that meets all the following criteria:

o Is a minor NCI that is not adversely impacting the health or well-being of 

an animal, and

o Is not a Direct or other Critical, and

o The facility/site is willing and able to correct the issue quickly, and
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o Was not previously listed as a Teachable Moment or cited at the site 

within the last two years

3. An NCI that should be cited, includes but is not limited to, any issue that:

o Is noncompliant and does not meet the criteria to be a Teachable 

Moment, or

o Was previously cited or identified as a Teachable Moment at the site 

within the last 2 years, or

o Is a Direct or other Critical, or

o Falls under a section of the Regulations or Standards that is already being 

cited. For example, if you are already citing 3.6(a)(vii) for insufficient 

shade, then any other NCI identified under 3.6, such as 3.6(c)(2) for 

compatibility, would be cited and would not qualify as a Teachable 

Moment. 

2.4.2.1. Use of Teachable Moments

Teachable Moments are not appropriate, and are not to be used:

• During a Prelicense or New Site Approval inspection

• At a facility/site with any of the following: 

o 4 or more NCIs identified even if one or more of these NCIs would qualify 

as a Teachable Moment, or

o Directs or other Criticals, and/or Repeats, or

o Citation(s) for refusal of inspection or interference within the last 2 years, 

or

o For a licensee/registrant with an open IES investigation, contact the SACS 

to discuss

2.4.2.2. Special Considerations

Note the following:

• On the first inspection after a license is issued, limit Teachable Moments to 

recordkeeping and identification issues

• On the first inspection after registration, use of Teachable Moments is 

appropriate

NOTICE

If an inspector is considering making a veterinary care noncompliance a 

TM, he/she needs to consult with the SACS.
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2.4.2.3. Documenting Teachable Moments

The inspector must enter the Teachable Moments into the Teachable Moments 

screen in eFile:

• Enter the appropriate section number of each Teachable Moment, and a 

brief description of the Teachable Moment

EXAMPLE Teachable Moment for 3.1(c):

Not enough detail: Dirty den boxes/carpet strings

Too much detail: Two pens in the Yorkie area in the top barn (# 3 

and 4) have mild staining around the den box opening and should 

be cleaned more frequently. In 2 pens in the whelping area, # 6 

and 8, housing 2 litters of poodles, there are carpet 

strings/excessive wear on 25% of each carpet. The owner did not 

want to disturb the new mother for the last couple days but has a

plan to replace the whelping carpets with the pups tomorrow.

Appropriate detail: Two pens with staining at den box door need 

more frequent cleaning & 2 whelping boxes with worn carpets 

need carpets replaced.

The inspector must provide a copy of the Teachable Moments to the 

licensee/registrant.

The inspector must review all previous Teachable Moments in eFile prior to the 

next inspection.

New NCIs Cited

If an NCI(s) is cited in the Inspection Report narrative, the citation should include 

the following four parts:

1. The section number and most specific subsection letter/number of each 

noncompliance

2. A clear, detailed description of the noncompliance including, when 

appropriate, the number of animals affected

3. An explanation of why the item is a noncompliance and/or the impact it is 

having on the animals

4. A correction deadline and a “general” description of what the licensee/ 

registrant should do to correct the problem and assure that it does not 

continue/recur. This description should not be worded in such a way that it 

could be interpreted that AC is mandating how an NCI is going to be 

corrected. A correction deadline should be appropriate to the severity of the 

NCI, and unless animal welfare will be put in jeopardy, be realistic as to what 

the facility can accomplish.

Use “Direct” or “Critical” NCI designation, if appropriate.
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Repeat NCI

NCIs cited in the same section and subsection on the last routine inspection or 

cited at least 2 times within the past three years will be automatically designated 

as a “Repeat” in eFile. For Attempted Inspections, Section 2.126(b) or 2.38(b) 

cited on the last inspection or the third citation in two years will be automatically 

designated as a “Repeat” in eFile. It is the inspector’s responsibility to make sure 

that the “Repeat” designation is correct.

Remember: Do not include correction dates for Repeat NCIs.

Recurring/Chronic NCI

A recurring or chronic noncompliant item is the same or a similar noncompliance 

that is not found on consecutive inspections, i.e., it is cited on one inspection, 

corrected by the next inspection, then re-occurs on the third and/or a 

subsequent inspection.

The recurring noncompliance can be:

• A noncompliance of the same section and subsection of the Regulations or 

Standards

• The same noncompliance with the same section and subsection of the 

Regulations or Standards but identified for a different species

• The same or a similar noncompliance as cited earlier

Some factors to consider when deciding if the NCI is recurring or chronic include, 

but are not limited to:

• Have you discussed the development of an active program or system of 

maintenance with the licensee/registrant?

• Have you discussed the NCI with a person of higher authority at the facility?

• Have you noticed a pattern?

• How far back was the last time the NCI was cited?

• How many inspections have been conducted between the recurrences?

NOTICE

If a noncompliant item falls into more than one section or subsection, cite the 

noncompliance only in the most applicable section or subsection for each 

species affected.

NOTICE

On Prelicense Inspections or New Site Approval Inspections, an NCI should 

not be designated as a “Repeat”.
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• What is the severity of the NCI?

Use your professional judgment in deciding what action to take, such as:

• Citing the NCI as a new noncompliant item

• Citing the NCI as a Repeat NCI

• Discussing the NCI with your SACS

“Critical” NCI Identified

Critical NCIs are the following:

• Direct NCIs (see description below)

• NCIs that had a serious or severe adverse effect on the health and well-being 

of the animal. Examples include, but are not limited to:

o Lack of an attending veterinarian with documented adverse effects on 

the health or well-being of an animal that require immediate veterinary 

care

o Studies involving more than momentary pain and distress to an animal 

that are conducted at research facilities without an approved protocol 

and without an appropriate response from the Institutional Animal Care 

and Use Committee (IACUC)

o Failure of an IACUC to meet and/or conduct facility and program reviews 

for a period of time equal to or greater than 1 year resulting in 

documented, adverse effects on the health or well-being of an animal

o Actions or inactions of unqualified personnel resulting in documented, 

adverse effects on the health or well-being of an animal

o Handling violation that resulted in death or serious injury to an animal

o Escape of an animal resulting in adverse effects on the health or wellbeing of the animal (NOTE: this includes those situations when an animal 

is not recovered)

• Inspection refusals and situations where APHIS has been unable to inspect 

the facility for a significant amount of time due to chronic unavailability for 

inspections

• Records intentionally falsified to mislead APHIS or another government 

agency

• NCI resulting in an injury requiring immediate medical attention or death to a 

human

• Handling an animal in a manner that results in an animal attack or physical 

contact between an animal and a member of the public, depending on the 

circumstances, such as where the incident adversely affected the health or 

well-being of the animal, or the circumstances or practices that caused the 

incident posed a high risk to the animal and/or the human and could have 
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led to serious injury or death to the animal and/ or the human

• Interference with, harassment, abuse, or threatening to harass or abuse an 

APHIS official in the course of carrying out his or her duties

• Obtained an animal from any person who is required to be licensed but who 

does not hold a current, valid, unsuspended license and knew both 1) that 

the person the animal was obtained from does not hold a license, and 2) that 

the person was required to hold a license

• Knowingly obtaining random source dogs or cats from a prohibited source, or 

obtaining animals by use of false pretenses, misrepresentation, or deception

• Engaging in regulated activity with a suspended or revoked license

“Direct” NCI Identified

A “Direct” noncompliance is a Critical noncompliance that is currently (at the 

time of the inspection) having a serious or severe adverse effect on the health 

and well-being of the animal.

The severity of an NCI at the time of a prior adverse incident has no impact on 

whether an NCI should be marked as a Critical or a Direct. The determining 

factor for a Direct is whether it has a current serious or severe adverse impact at 

the time of the inspection.

See Appendix C - NCI/Direct/Critical Noncompliance Examples.

Correction Date Guidelines

When assigning a correction date, note the following:

• If the “Direct” NCI was corrected at the time of the inspection, a correction 

date is not necessary

• For an egregious Direct noncompliance, the correction date should be very 

short, e.g., 1 day, and the reinspection should occur within a short period of 

time after the correction date to verify the correction and ensure animal 

welfare

• The correction deadline for a “Direct” noncompliance should never exceed 

14 days

A complete or focused reinspection of a facility with a “Direct” NCI must be 

completed within 14 days of the inspection date. You must conduct a 

reinspection at the facility even if the “Direct” NCI was corrected during the 

inspection.

NOTICE

On Prelicense Inspections, NCIs should not be designated as “Direct.”
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Direct NCI on a New Site Approval Inspection

If a Direct NCI is identified on a New Site Approval inspection:

• Designate the NCI as a “Direct”, and

• Assign an appropriate correction date, and

• Inform the licensee that an inspection will be conducted on or after the 

correction date to see if the Direct NCI was corrected

“Veterinary Care Direct” NCI Identified

Not every veterinary care NCI affecting an animal is a Direct.

A veterinary care noncompliance is a “Direct” if:

• The noncompliance is currently (at the time of the inspection) having a 

serious or severe adverse effect on the health and well-being of the animal, 

and

• The licensee/registrant has not sought veterinary care for the animal prior to 

the inspection

When citing a veterinary care “Direct” NCI:

• Include the ID of the animal if applicable and a description of the animal 

(species, breed, color, sex, age, etc.) in the NCI narrative

• Take a photo of the entire animal and a photo(s) and/or video of the area 

cited in the NCI

• A correction date, if given, should be very short, e.g., 1 day

• If the animal(s) has been taken to the veterinarian and care has been 

provided, including humane euthanasia when directed by the veterinarian, 

prior to your completion of the inspection, note in the narrative that the 

animal(s) was evaluated and treated by a veterinarian

Do not interfere with the licensee obtaining immediate veterinary care for an 

animal if needed.

For a veterinary care Direct corrected at the time of the inspection, note that the 

Direct was corrected on the original Inspection Report.

Handwritten or “Word” Inspection Reports

If you are unable to complete the Inspection Report in eFile, then complete the 

Word Template on your laptop or handwrite a report. In the event that your 

laptop is unavailable, carry several hard copies of the template.

If you completed a handwritten or Word Inspection Report:

• Enter the Inspection Report into eFile as soon as possible but no later than 5 

business days after the inspection
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• On the eFile Inspection Report:

o Do not put a statement that this is electronic or transcribed version of 

the original Inspection Report

• If the eFile Inspection Report is exactly the same as the handwritten or Word 

Inspection Report, a copy does not have to be sent to the licensee/registrant

• If the eFile Inspection Report and the original handwritten or Word 

Inspection Report are different, for example, all the dates are not the same, a 

copy must be sent to the licensee/registrant

For more details on Handwritten Inspection Reports, see Section 3.3.18.

Airport Inspections

The inspector is not required to deliver airline Inspection Report with no NCIs at 

airports at the time of the inspection. The no NCI Inspection Report may be sent 

by regular mail or emailed to the appropriate airline corporate office (Inspector 

must obtain an email address from the airline facility representative). See 

Chapter 4 –Airport Inspections for details.
--- Animal Care Inspection Guide ---

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2.5. Inspection Photographs

Photographs/Videos Documenting Noncompliances

Photographs or videos must be taken to document photographable 

noncompliant item(s) in all of the following situations and only in these 

situations unless instructed otherwise by your SACS:

• Direct, Criticals, or Repeats NCIs (if photographable)

• NCIs cited at a facility with an ongoing Investigative and Enforcement 

Services (IES) investigation and/or case pending with the Office of the 

General Counsel

• NCIs where there is a disagreement between you and the licensee/registrant 

and the licensee/registrant has indicated he/she will, or is likely to, appeal 

the citation

• All NCIs cited at commercial airline carrier inspections

• Veterinary Care NCIs involving animals:

o Photograph(s) or video(s) every animal covered by the citation

o Photograph(s) or video(s) the entire animal for identification purposes 

and photo(s) of the issue cited in the NCI

o Photograph labels must clearly identify the animal

• NCIs cited on the Third Prelicense Inspection for an applicant who was not 

previously licensed and is applying for a new (3 year) license since the NCI(s) 

may be appealed

• For a licensee who is currently licensed and is now applying for a 3-year

license:

o Any Repeat, Critical, or Direct NCIs documented on the First and/or 

Second Prelicense Inspection

o Any NCIs cited on the Third Prelicense Inspection since the NCI(s) may be 

appealed

For veterinary care citations, take photograph(s) or video(s) of every animal 

covered by the citation, including matted dogs. 

For facility citations, such as pens with broken wire, take a few representative 

photographs to prove that there was an NCI but not a photograph of every cage 

or area.

Photocopy, scan, or photograph records that:

• Document a Repeat, Direct, Critical, or transportation noncompliant item

• May be fraudulent
--- Animal Care Inspection Guide ---

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If copies of research facility records, protocols, or IACUC minutes are going to be 

photographed and removed from the facility, the facility will be afforded the 

opportunity to review/redact the records for proprietary business information. 

The inspector should allow the facility 24 to 48 hours for this purpose.

Label and upload all photograph(s) or video(s) that are to be retained into eFile

as soon as possible, but no later than 2 weeks after the inspection. Delete any 

inspection photos that you are not uploading into eFile in connection with an 

NCI. Do not store or save unused photos.

SACS may have inspectors take additional photographs, in addition to the 

required photos listed above.

Showing Photos during Exit Interview

The inspector should show the photographs taken during the inspection to the 

licensee/registrant on the inspector’s laptop at the time of the exit interview. 

This is to be used as a tool to clarify an NCI(s) for the licensee/registrant and to 

create an open dialog around correction.

Licensee/Registrant Requesting Photographs

A licensee/registrant may request a copy of the photographs taken during the 

inspection process. If the licensee/registrant requests a copy of any 

photograph(s), the inspector should email the requested photographs that were 

uploaded into eFile to the licensee/registrant, after they have been uploaded. If 

the number of photos requested cannot be reasonably emailed due to the size 

or quantity of the photographs, a flash drive containing the remaining 

photographs should be supplied by the inspector.

For licensees/registrants without email access, a reasonable number of 

photographs can be printed by the inspector (no more than three pages of 

photos). If more photographs were taken than can be reasonably printed by the 

inspector, a flash drive containing the remaining photographs should be supplied 

by the inspector. If other reasonable accommodations are needed, the 

individual accommodation is to be approved by the inspector’s SACS prior to 

distribution of the photographs.

Only photographs that have been uploaded to eFile should be supplied by the 

inspector to the licensee/registrant. 
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2.6. Inspection Inventory

The animal inventory is an important component of the inspection. This is the 

formal record of how many animals of each species Animal Care personnel 

observed/inspected during inspection. It is important that this is accurate, and 

care must be taken both during the inspection and when entering this 

information into eFile.

Before the Inspection

• Review and print or download a copy of the last inspection inventory prior to 

going to the facility

• Familiarize yourself with the natural history and specific needs of any animals 

that you are likely to encounter on that inspection (if you aren’t already)

During the Inspection

2.6.2.1. Countable Species

Whenever possible, inspectors must count the numbers of animals for each 

species. Make sure to keep accurate notes throughout the inspection. For 

species that are countable, make sure you compare your numbers to the 

facility’s record of animals on hand.

If there are any discrepancies make sure to ask the facility representative about 

those differences. It could be that one or more animals are currently away from 

the facility, but this may also indicate an error in their record-keeping or in the 

inspector’s count.

Compare the current record of animals on hand to the prior inventory. If there 

are additions or animals that are missing, make sure to carefully check the 

facility’s acquisition/disposition records to make sure those animals are 

accounted for. 

2.6.2.2. Difficult to Count Species

Some animals are difficult to count during inspection. This can occur when:

• Animals are kept in large groups (e.g., herding animals)

NOTICE

Because the inventory is a record of what Animal Care inspectors observed, 

the inventory included with the report may be different than the total 

number of animals maintained by the facility. For example, differences can 

occur when conducting a Focused Inspection on a few individual animals or 

specific taxa only, or if there are animals away from the facility during the 

inspection (e.g., those away on traveling exhibition or animals at an off-site 

veterinary clinic for care).
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• Species that are prone to piling on top of one another (e.g., harem housing 

for guinea pigs)

• Nocturnal animals in dimly lit enclosures

In these cases, inspectors should attempt to count animals during the inspection 

and keep notes as normally required. Following the physical inspection:

• Evaluate the facility’s method of record keeping and compare your numbers 

to the facility’s numbers of animals on hand

• Some discrepancy between these two numbers is likely due to the difficulty 

in counting

• The inspector’s numbers and the facility’s numbers should be within 10% of 

each other

• If there is greater than a 10% difference, the inspector should ask the facility 

follow-up questions, then:

o If the inspector is satisfied with the facility’s explanation, the facility’s 

animal numbers should be recorded on the inventory

o If the facility and inspector cannot come to agreement on the inventory 

numbers, the inspector should contact his/her SACS for instructions on 

how to resolve the disagreement

2.6.2.3. Species/Circumstances where Accurate Counts are Impossible

Occasionally animals are not able to be accurately counted during the inspection. 

For example, this can occur when:

• There are nocturnal animals in nest boxes or hide areas

• There are burrowing animals that are all underground during inspection

• There are large numbers of the same species in expansive habitats (e.g., 

fallow deer at some drive through parks)

In these circumstances, the animals can and should be included on the inventory 

provided that they were included in the inspection. As long as the enclosure, 

diet, food storage/prep areas, veterinary care records, etc., were inspected, 

those animals should be included on the inventory. 

Under these circumstances, the inspector should closely evaluate the facility’s 

required records, including records of acquisition, disposition, and animals on 

hand. If the facility records are accurate and contain all of the required 

information, the numbers of animals on hand provided by the facility should be 

used for inventory purposes. 

If the facility does not have the required records, or the records they have are 

missing required information, this should be documented either as a teachable 

moment or as a noncompliance on the Inspection Report, consistent with the 

guidance on Teachable Moments. When this occurs, you should estimate the 

animal numbers present and use that number on the inventory; it should be 
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made clear in the Teachable Moment or on the Inspection Report that the 

numbers were estimated.

Occasionally none of the individual animals may be visible during the inspection. 

If that occurs on multiple consecutive inspections, consider ways that you can 

increase your chances of visualizing animals during the inspection. That may 

involve inspecting at a different time of year (e.g., hibernating animals) or 

coming back to that enclosure later in the day (e.g., for nocturnal animals). Your 

SACS may have additional suggestions relevant to a particular facility.

2.6.2.4. Inventory on Focused Inspections 

When conducting a Focused Inspection, only list those species and animal counts 

that you inspected on the inventory. Either enter a new inventory for the 

Focused Inspection or copy the previous inventory and delete the species not 

inspected. Do not copy the previous animal inventory and leave species that 

weren’t inspected. For inspections that are focused on records only, your 

inventory should report no animals.

After the Inspection

The inspector is required:

• To enter the animal inventory into eFile

• To discuss and agree upon animal numbers with the licensee/registrant 

during the exit interview

• To provide the animal inventory list as part of the Inspection Report 

• The inventory must be entered into eFile and finalized. This should be 

completed as soon as possible and must be completed no later 5 days 

following the conclusion of the inspection. SACS may grant an extension to 

this deadline if there are extenuating circumstances preventing timely 

finalization of the inventory. 

2.6.3.1. Difficulty Locating a Species in eFile

If you are having trouble locating a species in eFile, here are a few tips:

• Check your spelling. Spelling matters here. Check the spelling and if that 

doesn’t work, try varying any hyphens or apostrophes in the name

• Try searching alternate common names. For example, many licensees still 

use the outdated name “Coatimundi” when referencing the South American 

Coati (Nasua Nasua). If you search Coatimundi, eFile will not return records.

• Search partial names 

• Search the scientific name (genus and/or species)

• If you still can’t find a particular species in eFile, reach out to your SACS for 

assistance. If together you still can’t find it, reach out to the Animal Welfare 
--- Animal Care Inspection Guide ---

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Operations (AWO) Inventory Support Team. If it turns out that the species is 

currently missing from eFile, this team will need to request the addition.
--- Animal Care Inspection Guide ---

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2.7. Exit Interview

An exit interview is required for all inspections (complete or focused), unless 

your personal safety is at risk, or harassment, verbal abuse, or other factors are 

interfering with the inspection process.

Conduct an in-person exit interview with the draft Inspection Report in hand if 

the licensee/registrant requests the opportunity to review the NCI narrative(s) 

prior to finalization of the Inspection Report.

Take as much time as necessary during the exit interview to:

• Discuss animal welfare and the AWA Regulations and Standards with the 

licensee/registrant

• Summarize everything that occurred during the inspection, and provide the 

licensee or registrant an opportunity to present additional information that 

may influence the determination of compliance

• Discuss each noncompliant item in detail with the licensee/registrant or 

facility representative. If the licensee or registrant provides information or 

documentation that influences an NCI on the current version of the 

Inspection Report, modify the report to accurately reflect the compliance of 

the facility before it is issued.

• Show the licensee or registrant any photos/videos taken during the 

inspection to communicate exactly what the noncompliance is (See 

Licensee/Registrant Requesting Photographs)

• Inquire about what the licensee/registrant might consider doing to correct 

the problem and discuss options with him/her (if asked)

• Discuss the animal inventory and animal counts with the licensee. Ensure all 

species and numbers are correct prior to finalizing the inventory report and 

provide a copy of the finalized inventory report to the licensee with the 

Inspection Report.

Unless an exit interview could not be completed (for example, it is unsafe or 

there may not be an exit interview for a carrier inspection at an airport), a 

statement must be added to the Inspection Reports through eFile stating, “This 

inspection and exit interview were conducted with ____.” Do not use actual 

names of facility representative or personnel, only titles. 

NOTICE

If the Inspection Report is to be delivered by email or certified mail, you must 

still conduct a detailed and thorough exit interview. Any item that you will be

citing on the Inspection Report or any Teachable Moments must be discussed

during the exit interview.
--- Animal Care Inspection Guide ---

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2.8. Delivery of the Inspection Report

You must hand deliver Inspection Reports with Direct NCIs unless you obtain 

SACS approval to do otherwise.

Hand delivery is preferred for all inspections except for Attempted Inspections. 

However, Inspection Reports may be delivered via email or certified mail, if 

necessary. 

Inspection Reports with no NCIs may be sent by regular first-class mail or email; 

it is not necessary to send by certified mail.

First Attempted Inspection Reports may be sent by regular first-class mail or 

email. Second Repeat Attempted Inspection Reports must be sent by email or by 

both certified mail and regular mail.

For all delivery methods, the Inspection Report must be delivered or sent to the 

facility as soon as possible but no later than 5 business days after the inspection. 

Obtain SACS approval if you cannot meet this deadline.

If sent by email, the inspector must convert the Inspection Report to a PDF, so it 

cannot be altered and must request an email reply verifying receipt of the 

Inspection Report by the facility. If an email reply is not received within 5 

business days from the day it was sent, the inspector must deliver the report by 

another method so that receipt can be verified. 

When sending an Inspection Report by certified mail, enter the certified mail 

information into eFile. Be sure to include the CID # on the Green Card and scan 

the Certified Mail receipt into Part 3 of the IR in eFile

Signature on the Inspection Report

The inspector and the licensee/registrant are not required to sign the IR.

Any licensee/registrant with a disagreement about the inspection findings may 

follow the inspection appeals process. 
--- Animal Care Inspection Guide ---

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2.9. ACI Team Inspection with a VMO after a Veterinary Care Direct

After a veterinary care Direct is identified on an inspection by an ACI:

• A VMO must be present on the next full inspection of the facility

• The ACI may choose to take a VMO on the Focused Inspection to follow up 

on the Direct veterinary care NCI
--- Animal Care Inspection Guide ---

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2.10. Risk Based Inspection System (RBIS)

You must inspect the following facilities on or before the deadline date given in 

eFile:

• Facilities with Direct NCIs

• Facilities with High Inspection Frequency (HIF)

• Research facilities which must be inspected at least once every fiscal year

If you cannot, contact your SACS prior to the deadline so that another inspector 

can be assigned to conduct the inspection.
--- Animal Care Inspection Guide ---

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2.11. Deciding Not to Conduct an Inspection

In some circumstances when you arrive at the facility, you may determine that it 

is not appropriate to conduct an inspection. If you are unsure whether you 

should conduct an inspection, or if this is a recurring issue at this facility, contact 

your SACS. If you do not conduct an inspection, document this visit on your Time 

and Attendance Report. Do not cite it as an Attempted Inspection.

Examples of situations where you should not conduct an inspection include, but 

are not limited to:

• Contagious disease in the animal facility such as parvovirus (you may want to 

contact the attending veterinarian for more information)

• Illness of the licensee with no other responsible person available

• Personal events such as weddings, funerals, doctor/veterinarian 

appointments, or family emergencies

• Religious holidays
--- Animal Care Inspection Guide ---

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2.12. Attempted Inspection

An Attempted Inspection occurs when an authorized person is not available to 

accompany the inspector, and no inspection is conducted.

If an authorized person is not present at the facility, follow the Attempted 

Inspection guidance in Chapter 4. If you are not able to contact the 

licensee/registrant or conduct an inspection, leave the facility, and cite section 

2.126(b) for licensees, carriers and intermediate handlers and section 2.38(b) for 

registered research facilities. In the citation narrative, write a brief description 

of what you did to contact the licensee/registrant, e.g., called all the contact 

numbers provided, knocked at the door, waited 30 minutes, etc.

Send the Inspection Report for the first citation of an Attempted Inspection by 

regular mail only or email. Send Inspection Reports citing Repeat Attempted 

Inspections to the licensee or registrant by both regular and certified mail or 

email. Convert any emailed Inspection Report to a PDF so that it cannot be 

altered.

If there is an adult at the facility, they can receive the Attempted Inspection 

Report and give it to the licensee. 
--- Animal Care Inspection Guide ---

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2.13. Prelicense Inspection

An applicant’s facility must meet all applicable Regulations and Standards to 

obtain a license. Prelicense Inspections are scheduled at a time agreeable to the 

applicant and the inspector. Do not conduct a Prelicense Inspection until all the 

applicant’s paperwork has been processed by Program Support and the 

inspector has been informed that the applicant may be inspected. See Prelicense 

Inspection Process in Chapter 4 for details on conducting a PL inspection.
--- Animal Care Inspection Guide ---

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2.14. Refusal of Inspection

If a licensee or registrant refuses to allow an inspection, ensure that you have 

clearly identified yourself as a USDA Animal Care inspector, and that the 

licensee/registrant is aware of the serious nature of this noncompliance of AWA 

Regulations. If you are sure that you are safe, ask this question once, “Are you 

refusing to allow the inspection?” If the licensee/registrant still refuses to allow 

an inspection, leave the premises, and complete an Inspection Report 

designating this as a Routine Inspection. Cite section 2.126(a) for licensees or 

registered transporters, section 2.38(b) for registered research facilities.

Document the specific circumstances of the refusal in the Inspection Report 

narrative: be specific as to date, time, and the identification of the person who 

refused to allow the inspection. Include any pertinent statements made by the 

licensee or registrant.

If two or more APHIS officials are present for the inspection and one is denied 

entry, document this as a refusal of inspection. Do not conduct an inspection.

Send the Inspection Report for a refusal to the licensee or registrant by both 

regular and certified mail.

Communicate any “refusal to allow inspection” with your SACS to develop a plan 

for a follow-up inspection.
--- Animal Care Inspection Guide ---

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2.15. Interference

If you are being harassed, abused (including verbally abused), or interfered with 

in the course of carrying out an inspection, inform the licensee or registrant that 

the inspection can only continue if the harassment, abuse, or interference stops. 

If the activity or behavior continues, you must discontinue the inspection 

process and leave the premises and cite it. 

Write a Routine Inspection Report citing all NCIs identified until the inspection 

was stopped and section 2.4 for licensees, section 2.25(c) for registered 

transporters, or section 2.30(d) for registered research facilities. This NCI should 

be designated as a Critical. In the narrative, be specific as to date, time,

identification of the person(s) involved and details of the harassment and/or 

verbal abuse, and/or interference.

An exit interview should not be conducted. This should be noted on the 

Inspection Report.

Send the partial Inspection Report to the licensee or registrant in such a way that 

it can be tracked, such as certified mail, UPS or FedEx. 

For any “interference with the inspection,” communicate with your SACS to 

develop a plan for follow-up inspections.

SAFETY

If you are being threatened, follow procedures to ensure your safety 

including, but not limited to, leaving the premises and calling 911, if 

necessary. After your personal safety is ensured, consult with your SACS with 

regard to future steps.
--- Animal Care Inspection Guide ---

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2.16. Correcting, Rescinding, and Amending an Inspection Report and/or Inventory 

Correcting, rescinding, or amending an Inspection Report and/or Inventory is 

done on a case-by-case basis under the direction of your SACS or the Animal 

Welfare Operations leadership team.

Correcting an Inspection Report and/or Inventory

An Inspection Report and/or Inventory that has been finalized and a copy has

not been given to the licensee/registrant yet, may be corrected by requesting 

through your SACS or SOTW that the Inspection Report and/or Inventory be 

reset to draft.

Rescinding and Amending an Inspection Report and/or 

Inventory

An Inspection Report and/or Inventory that has been finalized and a copy has 

been given to the licensee/registrant, may be corrected by requesting through 

your SACS or SOTW that the Inspection Report and/or Inventory be rescinded so 

it can be amended.

For an amended Inspection Report and/or Inventory:

• Do not put any statement on the Inspection Report that this is an amended 

Inspection Report

• Complete the Amended Inspection Report Letter using the template in 

Appendix A - Amended Inspection Report Letter

• Deliver the amended Inspection Report with the Inventory and Letter to the 

licensee/registrant using the approved methods of delivery

• If only the Inventory is amended, send a copy of the Inspection Report with 

the Amended Inventory and Letter

NOTICE

You may not add a Direct, Critical, or Repeat designation or an additional 

citation to an Inspection Report after it has been given to the licensee or 

registrant.
--- Animal Care Inspection Guide ---

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2.17. Inspection Report and Teachable Moments Review

The SACS or his/her designee must review the Inspection Reports and Teachable 

Moments in eFile as soon as possible but no longer than 21 days from the date 

the report is finalized.

Inspection Report Review 

Review Inspection Reports to ensure that, at a minimum:

• All required information is included and correct

• All subparts of the citation are included in the narrative

• NCI narrative provides facts supporting each element of the requirement, is 

objective and free of significant errors

• Directs, Criticals and Repeats are designated correctly

• The correct exit interview statement is included in the narrative section

• No information that should not be on the Inspection Report is in the 

narrative

• Photographs/videos are included if required

• Animal Inventory is included

Use the Inspection Report Review Checklist in Appendix A as a guideline for 

reviewing Inspection Reports.

Teachable Moment Review

Review the Teachable Moments to ensure that, at a minimum:

• The facility meets the criteria for the use of Teachable Moments

• The NCI is appropriate to be a Teachable Moment

• The description of the Teachable Moment is appropriate

• The Teachable Moment Form is completed properly

Use the Teachable Moments Review Checklist in Appendix A as a guideline for 

reviewing Teachable Moments.
--- Animal Care Inspection Guide ---

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General Inspection Procedures

Contents

3.1. Preparing for the Inspection 3-3

Translation Services 3-3

3.2. Conducting the Inspection 3-4

General Information 3-4

Inspection on Native American Land 3-5

Biosafety Measures 3-5

Animal Inspection – Specific Guidance 3-6

Facility Inspection — Specific Guidance 3-13

Miscellaneous Inspection Guidance 3-17

3.3. Completing the Inspection Report 3-21

General Information 3-21

Changes in Business Information 3-22

Action to Take When a Person, Facility, or Site is NOT in the 

eFile Database 3-22

Traveling (TRA) Site 3-23

Type of Inspection 3-23

Inspection Report Narrative 3-24

Examples of Citations 3-24

Information Inspectors Should Not Include in the Narrative 3-27

Repeat Noncompliant Item Identified 3-28

Direct Noncompliant Item Identified 3-28

Critical Noncompliant Item Identified 3-28

Noncompliant Item with Correction Time Remaining 3-28

No Regulated Animals Present 3-28

Non-regulated Animals 3-29

Correction Date 3-30

Prior to Printing the Final Inspection Report 3-32

Finalizing the Inspection Report 3-33

Handwritten Inspection Reports 3-33

Mistakes on the Inspection Report 3-34

Correcting or Amending the Inspection Report 3-35

Inspection Appeals Process [2.13] 3-36

3.4. Safety and Ethics Issues 3-38

Bribery Reporting Procedures—Inspector’s Responsibility 3-38

Bribery Reporting Procedures—Supervisor’s Responsibility 3-39

Gifts from Licensee/Registrant 3-39

Interference with the Inspection 3-39
--- Animal Care Inspection Guide ---

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DISCLAIMER

The Animal Welfare Inspection Guide is intended to be a reference document to assist the 

inspector. The Inspection Guide does not supersede the Animal Welfare Act (AWA), the AWA 

Regulations and Standards, AC policies and other guidance, the Required Inspection 

Procedures, standard procedures, or the inspector’s professional judgment. All inspection 

decisions must be justified by applicable sections of the AWA and/or the AWA Regulations 

and Standards.
--- Animal Care Inspection Guide ---

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3.1. Preparing for the Inspection

Review the appropriate information in order to conduct a thorough inspection.

Prior to the inspection, review the following information:

• Applicable sections of the Regulations and Standards

• Applicable sections of the Required Inspection Procedures, Specific Types of 

Inspections, and other sections of this Inspection Guide

• Pending investigations and prior enforcement actions if any

• Facility’s past Inspection Reports

• Animal Inventory

• Optimal Hours of inspection

• Other relevant resources (such as species-specific guidance if a facility holds 

a unique species)

Translation Services

If English is not the primary language of a customer and they have difficulty 

communicating effectively in English, Language Line Solutions is available to 

provide assistance with language and translation of documents at no cost to the 

customer. Language Line Solutions provides high quality over-the-phone or 

video remote interpreting services, and onsite interpretation and translation 

services. If you need assistance with interpretation or translation services to a 

regulated entity, please contact your Admin POC. 

NOTICE

For forms and worksheets that you may need during or after the inspection, 

see Appendix A. Forms and Worksheets.
--- Animal Care Inspection Guide ---

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3.2. Conducting the Inspection

Each inspector must develop a consistent method of conducting inspections to 

ensure that his/her inspections are thorough, accurate, and in accord with this 

Inspection Guide and the AWA and the Regulations and Standards.

General Information

The basic steps for conducting an inspection are outlined below. However, the 

exact sequence for conducting the inspection is at the discretion of the individual 

inspector.

• You should inspect a facility at different times of the year if possible, rather 

than inspecting the same month or season every year

• Upon arrival at the facility, be alert for unsafe conditions

• Prior to conducting the actual inspection:

o Contact the licensee/registrant or authorized representative

o Introduce yourself in a professional manner

o State the purpose for the visit

o Show your USDA badge and ID

o Provide a business card, if appropriate

• If the facility, e.g., zoo, theme park or wild animal park, has an admission 

gate or ticket window:

o Go to the admission gate/ticket window

o Identify yourself in a professional manner

o State the purpose of your visit

o Show your USDA badge and ID

• At most facilities, you will not be required to pay admission. However, if an 

admission fee is requested, you can ask to speak to someone in 

management. If you need to pay admission, contact your SACS for approval, 

NOTICE

Do not allow anyone to photograph or photocopy your government ID. If a 

facility wishes to verify your identity as a USDA inspector, they may call the 

Animal Care office in Fort Collins. If you are denied access to a facility or not 

able to conduct an inspection because a facility requires a photocopy of your 

government ID, this should be considered a refusal of inspection and cited on 

an Inspection Report.
--- Animal Care Inspection Guide ---

Savedate 12/7/2021 9:38 AM General Inspection Procedures 3-5

then charge the admission fee on your Purchase MasterCard (preferable), or 

pay the fee yourself and you will be reimbursed.

• If you do not find anyone at the facility, follow procedures for an Attempted 

Inspection (see Attempted Inspection in Chapter 2 and Chapter 4)

• For Traveling Exhibitor Inspections, see Traveling Exhibitor Inspection in 

Chapter 4

Inspection on Native American Land

If you conduct an inspection or conduct a search for unlicensed activity on Native 

American lands, contact the tribal leader prior to conducting the 

inspection/search to explain the purpose of your visit.

If the tribal leader refuses to allow you to conduct the inspection/search, leave 

the land, and contact your SACS or your Assistant Director.

Biosafety Measures

Biosafety measures when conducting an inspection include, but are not limited 

to, the items listed in Table 3-1. Follow the facility’s biosafety procedures. If the 

facility has no procedures or procedures that are less protective than the 

recommended biosafety measures, put on the recommended protective 

clothing, gear, and/or boots.

Table 3-1. Biosafety Measures When Conducting an Inspection

If you are inspecting: Then wear:

Dogs or cats Disposable shoe covers (required)

Disposable gloves (required if touching any animal,

change gloves between each animal or cage)

Ear plugs (optional but highly recommended for dog 

kennels)

NOTICE

Under certain circumstances, you may want to observe the exhibition, facility, 

or facility personnel prior to announcing your presence. If you need to pay 

the entrance fee, contact your SACS or SOTW for approval, then charge the 

admission fee to your Purchase MasterCard (preferable) or pay the fee 

yourself and you will be reimbursed. The observation should be done from 

areas accessible to the general public. Immediately after observing the 

exhibition/facility/personnel, you must announce yourself to the 

licensee/registrant or facility representative and arrange to complete the 

inspection and address any findings that you observed prior to announcing 

yourself.
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Coveralls (optional)

Elephants (TB positive or 

TB suspect)

Respirator (level N95 or better)

Macaques Respirator (level N95 or better) is required if within 

5 feet or less

Disposable shoe covers

Coveralls, preferably disposable

Full face shield and eye protection, such as safety 

glasses or goggles

Disposable gloves

Other nonhuman 

primates

Respirator (level N95 or better when nonhuman 

primates and other animals are suspected to be 

infected with TB indoors, or within 5 feet or less 

outdoors)

Animal Inspection – Specific Guidance

3.2.4.1. General Information

Basic steps or procedures when conducting an inspection of the animals include, 

but are not limited to:

• Approach all animals quietly and cautiously

• Ask if there are any other animals that you have not seen, such as those in 

quarantine, isolation, holding areas, off-site, or on loan or lease

• Be alert for escape routes for yourself in case of a dangerous situation

• Before approaching an animal, ask the facility representative:

o About the temperament of the animal

o If the animal is approachable

o Where is the safest place to be located

• Let the person accompanying you open and close gates and doors to prevent 

escapes

• Always have the person accompanying you go through the gate or door first 

as a safety measure

• Make sure all animals are safely secured
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• Observe handling techniques of personnel during prelicense inspections and 

during inspections of licensed and registered facilities, and note that:

o For licensed/registered facilities, the inspector should evaluate the 

handling experience and qualifications of the personnel 

o For applicants:

- Inspector should evaluate the handling seen during the prelicense 

inspection 

- The inspector should consult with his/her SACS and the appropriate 

Species Specialist if there are concerns about the applicant’s handling 

techniques and experience

• Observe the animals for their health and well-being:

o Avoid handling the animals unnecessarily

o Do not engage in diagnostic procedures

o If a dangerous animal needs close evaluation, ask the facility to make 

arrangements for the animal to be examined by a veterinarian

o If you need to closely examine a non-dangerous animal and it can be 

done safely, have the owner or handler restrain the animal

o Wear disposable gloves if you must handle any animals

• Stay behind or next to the facility representative

• Review husbandry practices

• Review supervisor and employee experience and training and ensure the 

facility has a sufficient number of employees [3.12; 3.32; 3.57; 3.85; 3.108; 

3.132]

• Review veterinary care practices and records as appropriate [2.40]

• Review public contact procedures [2.131]:

o Newborn and infant nondomestic cats four weeks (28 days) of age or 

NOTICE

You and the facility representative should work together to ensure your

safety around animals during an inspection. If you feel unsafe, ask the facility 

representative or designated authorized representative to correct the 

situation. If you feel you are in danger, safely leave the area.

NOTICE

Newborn and infant non-domestic cats 4 weeks (28 days) of age or younger 

should be housed in the controlled environment of a heated, clean and 

sheltered enclosure (such as a nursery), or in a clean, sheltered enclosure 

with the mother and any healthy siblings.
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younger (neonate or neonatal) have special handling and husbandry 

needs. Among other things, the AWA Regulations require licensees to 

ensure that they are handled safely and protected from harm. Because 

of their limited immunity, their health is at risk if they are exposed to 

other animals or offered for public contact. For more information, please 

read Tech Note, Handling and Husbandry for Neonatal Nondomestic Cats.

o For regulatory purposes, AC generally considers big cats to become 

juveniles when they reach roughly 12 weeks of age. Inspectors should 

not use this age as an absolute “cutoff date,” but rather should use it as a 

guideline when evaluating exhibits that allow public contact with big cats 

that are at or older than 12 weeks of age. At approximately 12 weeks of 

age dangerous animals, such as tigers, lions, bears, and wolves (See 

Appendix B - Dangerous, Potentially Dangerous, and Special License 

Animals) become too big, too fast and too strong to be used for public 

contact.

• Review the Attending Veterinarian approved plans such as the Exercise Plan 

for dogs [3.8], and the environmental enhancement plan for NHPs [3.81] (See 

Appendix A for the optional APHIS Form 7050 and the EEP Checklist)

3.2.4.2. Inspector Behavior Guidelines around Animals

Inspectors may be asked to do on-site inspections of circuses, zoos, animal 

sanctuaries, or other facilities that may house a variety of nondomestic animals. 

Inspectors should understand and follow appropriate behavior guidelines when 

evaluating nondomestic animals such as primates, nondomestic cats, elephants, 

marine mammals, or other exotic or wild animals. This section discusses 

appropriate inspector behavior when inspecting nondomestic animals.

An inspector should never enter the enclosures of dangerous or potentially 

dangerous animals unless the inspector personally verifies the animals are 

securely locked out of the enclosure.

Rules of behavior when inspecting nondomestic animals are:

• INTERACTION: Do not reach out to, or try to pet or feed the animals, no 

matter how friendly they may seem

• PROXIMITY: Do not stand within reach of them

o Big cats and non-human primates may reach out over 3 feet through

narrow spaces

• AGITATED BEHAVIOR: If the animal appears agitated because of your 

presence, make your observations quickly or from a greater distance

• LIMITING STRESS: Some animals become stressed or agitated around 

strangers. Standing in front of an enclosure and looking, staring, or pointing 

at an animal while discussing issues with the licensee may cause stress or 

agitation. It is best to discuss any issues that may pertain to that animal or 

its enclosure at a reasonable distance from the enclosure
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• YOUR REACTIONS: Try not to react if some animals vocalize or hit the fence 

or enclosure where you are standing. Many animals are looking for a 

reaction. Make your observations and quickly move on

3.2.4.2.1 Nonhuman Primates

Primates are social animals and have complex social behaviors. Staring directly 

at primates is considered a threat to them, and may cause them to be agitated, 

especially if they are in their behind-the-scenes night quarters. While most zoo 

primates are accustomed to people staring at them, the public is not allowed 

behind the scenes and staring may be more threatening to them in their offexhibit areas. Smiling at many species of primates may also be considered a 

threat, and while a primate may “smile” back, realize he is not smiling, but 

showing you his teeth, which may indicate a sign of aggression. Try not to point 

at the animals with your finger, and do not stand close enough to any enclosure 

that the primate may be able to touch or grab you. If a chimpanzee, gorilla, or 

orangutan were to grab any part of you with just one finger, it could cause 

significant injury or damage.

Great apes (chimpanzees, gorillas, or orangutans) may also spit water or throw 

fecal material or other items at strangers or at people they know but do not like, 

e.g., the veterinary staff. They may be obvious in picking up fecal material or 

items in their enclosure and throwing it in your direction; however, many wait 

until you turn your back, and can hit their targets with amazing accuracy.

Orangutans have a longer reach than the other great apes. Maintain an extra 

distance of greater than 4 feet from them as a margin of safety.

BEWARE: Macaques are unapparent carriers of Herpes B virus, which is deadly to 

humans without appropriate and immediate treatment. One drop of saliva or 

urine from a macaque shedding the virus splattered into a human eye or mouth 

or transmitted through a bite or scratch injury has been known to cause the fatal 

disease. If you are inspecting a facility with macaques, be sure to protect 

yourself from the possibility of a bite, scratch or spray of urine or feces from 

these animals. Some facilities require personal protective equipment such as a 

clear face guard or safety goggles, a surgical mask, gloves, and protective 

clothing when entering rooms housing macaques. When there are no protective 

equipment requirements, you must stay a minimum of 5 feet away from any 

macaque enclosure. Any inspection of macaque species within 5 feet or less of 

the animals or enclosures requires the use of a full-face shield, respirator, 

disposable gloves, footwear, and coveralls.

Inspectors must not enter rooms when facility employees are spraying, or 

cleaning enclosures or room surfaces or performing functions that could result in 

splash hazards or aerosol production.

3.2.4.2.2 Big and Small Nondomestic Cats

Cats are sensitive animals and may become agitated in the presence of 

strangers. Cats of all species will flatten their ears when angry or agitated. 

Recognize this behavior and step away from the enclosure before the cat 
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becomes more agitated and either vocalizes or hits the enclosure fence. Talking 

to the animals when they are agitated rarely soothes them, as you are a stranger 

in their environment.

Many cats will spray-mark their environment. Often big cats, especially tigers 

and lions, will exhibit this behavior towards people. The cat may be standing 

near the front of the enclosure or will calmly walk to the enclosure fence, often 

near the area where people are standing. They will then turn, lift their tail, and 

spray urine up to 10 feet away. If you notice this behavior, you will have only a 

moment to step out of range.

BEWARE: Many enclosures, especially night quarters or gates to enclosures, 

have a small space between the bottom of the enclosure, fence, and the ground, 

or around gates or feeding chutes. Livestock wire fencing has ample spaces in 

the fencing itself. Big cats (and small nondomestic species) are able to reach 

through these spaces and have been known to attack unsuspecting persons who 

are standing too close. Stay a minimum of 3 feet away from all big cat 

enclosures. Many licensees will have a protocol and an obvious painted “safety 

line” on the floor or a barrier running adjacent to the big cat enclosures. If 

entering a narrow hallway between two cages, ensure you know the 

whereabouts of the cats, and be careful not to back up against one enclosure 

with a cat present if you are startled by another cat across the hallway. Try to 

maintain your distance from all enclosures when in tight quarters, and if the 

situation seems dangerous, ask the keepers to shift the cats to enclosures away 

from the hallway while you conduct your inspection.

3.2.4.2.3 Elephants

All elephants have the potential to be dangerous. Elephants can reach up to 8 

feet with their trunks. Staying back a minimum of 8 feet, even if the elephant is 

chained or behind a barrier, will help to ensure your safety. Keep the handler 

between you and the elephant(s) at all times. Work with the handler to 

determine the best (safest) place to make your observations, while maintaining 

an 8-foot distance from the elephant’s trunk. When inspecting elephants, 

always have an escape route planned. When inspecting other areas of the 

elephant barn and the yard(s), ensure a handler or facility representative always 

accompanies you. Always ensure that you know the location of the elephant(s) 

during the entirety of your inspection.

Elephants are usually handled in two basic ways: protected contact or free 

contact. Protected contact involves managing an elephant with a barrier 

between the handler and the elephant. In protected contact, handlers do not 

share the same space as the elephant. Free contact involves managing the 

elephants without a barrier between the handler and the elephant. In free 

contact, the handlers share the same space as the elephant. In this management 

system, handlers commonly use an ankus when working with the elephant. An 

ankus is a device that resembles a short boat hook and has a spike and a hook.

In a protected contact system, ask the handler(s) to position the elephant(s) 

behind a barrier so that an inspection of the animal’s feet, skin, teeth, and other 
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parts can be conducted as needed. Although the elephant is behind a barrier, be 

cognizant of the elephant’s trunk and maintain an 8-foot distance from the head 

of the elephant to ensure your safety. If needed, use your camera to get a closer 

view. In a protected contact management style, handlers will not enter the 

enclosure with the elephant(s), and you must not either.

In a free contact system, the handler will often invite the inspector to get up 

close to the elephant(s). Remember to keep the handler between you and the 

elephant, have an escape route planned and maintain your 8-foot distance 

(using your camera for a closer view, if needed). Do not go into an enclosure 

with an animal handled in free contact. Ask the handler to position the elephant 

in a manner that will allow you to conduct an inspection from a safe location and 

in a safe manner.

Regardless of the contact system, if the elephant shows signs of agitation 

(vocalizing, flapping ears, pulling itself to its full height, jerking its head up and 

down) or is not responding appropriately to the handler’s commands, 

immediately leave the area and let the handler manage the problem. If 

necessary, find a location to continue observing the animal that will maintain 

your safety. Remember, elephants have the potential to be dangerous. Being 

cognizant of their location, behavior, and management style is essential to 

conducting a safe and thorough inspection. Working with the handlers to 

conduct the inspection is essential, keeping in mind that you are putting yourself 

at risk when you go near an elephant, even if the handler appears to be 

exceptionally competent.

3.2.4.2.4 Hoofstock

Nondomestic hoofstock (eland, oryx, nilgai, kudu, bison, deer, etc.) may be 

dangerous. Bison and other bovid-type nondomestic hoofstock, as well as 

cervids (generally bucks), have been known to charge or butt people without 

warning. When inspecting nondomestic hoofstock, ensure a sturdy fence is 

between yourself and the animals, and do not stand within reach of these 

animals. It is rarely necessary to enter a hoofstock enclosure, but if absolutely 

necessary, ensure the handler/keeper is always between you and the animals, 

and consider an escape route before entering the enclosure. Whenever 

possible, enter veldt-type enclosures (large pens housing multiple species of 

hoof stock) in a vehicle.

Camels and llamas may spit when upset, and llamas have been known to push 

upon, and knock over people. Note that llamas will flatten their ears when 

getting ready to spit. Camels may be dangerous, especially intact males. Male 

camels have reached over enclosures and bitten or lifted people off the ground.

Nondomestic hoofstock, have varying flight distances, which is the distance they 

will allow someone to approach before they flee or bolt. It is undesirable to 

upset the hoofstock in an exhibit, and inspectors must maintain a reasonable 

distance between themselves and the hoofstock living in that enclosure. Allow 

the keepers to suggest a distance for you to observe that is appropriate and nonthreatening to the animals.
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BEWARE: Some facilities may house ostriches with their hoofstock. Ostriches, 

especially males, may be deadly, and have been known to attack and seriously 

injure or even kill people, often unprovoked and without warning.

Their kick is powerful, and they kick high and forward, aiming directly in front of 

them. Never enter a mixed exhibit on foot where male ostriches are housed. 

Cassowaries are also very dangerous birds. Never enter an enclosure housing a 

cassowary.

3.2.4.2.5 Potential Rabies Exposure

If you are inspecting facilities where you will be entering exhibits or enclosures 

which contain free-roaming (or free-flying) mammals, such as raccoons, skunks, 

or bats, and you feel there is a potential for being bitten or scratched, or you feel 

there is potential for rabies exposure via the aerosol route (no matter how 

remote), you should wear personal protective gear, such as a mask or respirator 

and goggles, and have pre-exposure rabies prophylaxis.

3.2.4.3. Stopping the Inspection for Veterinary Care

If during an inspection, you notice an animal that needs immediate veterinary 

care, instruct the licensee to seek veterinary care for the animal and stop the 

inspection if necessary.

Examples of when an animal may need immediate veterinary care include, but 

are not limited to:

• Unresponsive animal

• Pale pink or white gums

• Labored breathing/open-mouthed breathing

• Fractured or dislocated limb

• Severe bleeding or injury

• Severe, watery, or bloody diarrhea

3.2.4.4. Pet Dogs

Because personal pet dogs of the licensee often end up being bred and moved to 

the kennel, the following guidance should be followed if the personal pet dogs 

are housed on the same premises as the kennel or in the kennel itself:

• All intact females, capable of breeding, should be listed on APHIS Form 7005

• Pet dogs do not need to be tagged, although they should be assigned a tag 

number on APHIS Form 7005

• The only time there would be a concern about disease transmission would be 

if the pet dog was sick and was in need of veterinary attention

• The only time there would be a concern about containment is if there was a 

history of dogs getting hit by cars or injuries related to non-confinement
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• Inspectors should discuss with licensees the issues of non-containment and 

disease transmission, e.g. Brucella canis, Parvovirus, etc.

3.2.4.5. Barn Cats

If a licensee has barn cats, i.e., loose cats used as pets and/or for pest control, 

not for regulated breeding purposes, the barn cats are not covered because barn 

cats rarely end up being used for regulated purposes. Therefore, they do not 

need to be inspected or follow any of the Regulations or Standards. However, if 

the barn cats have a negative effect on the regulated animals, this should be 

cited under the applicable Standard for the species impacted, not the Standards 

for cats.

Examples of negative effects include, but are not limited to:

• Cats getting into the food supply

• Cats contaminating the animals’ food and/or water

• Cats harassing or causing stress to a regulated animal such as in a prey/ 

predator situation

• Sick cats possibly transmitting disease

If the licensee allows the barn cats to have kittens, you should determine if the 

disposition of the kittens will be a regulated activity. 

Facility Inspection — Specific Guidance

The inspector must develop a consistent method for inspecting facilities that 

ensures inspections are thorough, accurate, and all citations are based on the 

Regulations and Standards. 

Guidance on specific issues related to facility inspection include:

3.2.5.1. Housing Facilities – Indoor, Sheltered or Outdoor

When determining if a facility is indoor, sheltered, or outdoor, the inspector 

must assess the facility in a stepwise fashion beginning with the indoor housing 

definition. If a facility does not meet this definition, then the inspector should 

next consider the sheltered housing definition if the animals housed therein are 

dogs, cats, or nonhuman primates. A facility is only to be considered an outdoor 

housing facility if it “does not meet the definition of any other type of housing...”

3.2.5.1.1 Indoor Housing

The AWA Regulations define Indoor Housing as: any structure or building with 

environmental controls housing or intended to house animals that:

1. Is capable of temperature control within the limits for species of animal 

therein, maintaining humidity levels of 30 to 70 percent, and rapidly 

eliminating odors from within the building; and

2. Has a continuous connection of a roof, floor, and walls (a shed or barn set on 
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Savedate 12/7/2021 9:38 AM General Inspection Procedures 3-14

top of the ground does not have a continuous connection between the walls 

and the ground unless a foundation and floor are provided); and

3. Has at least one door for entry and exit that can be opened and closed (any 

windows or openings which provide natural light must be covered with a 

transparent material such as glass or hard plastic)

A housing facility must meet the conditions for all aspects of the definition of 

“indoor housing facility” to be considered an indoor housing facility under AWA 

regulations. If the temperature, ventilation, and humidity are not controlled in 

an indoor housing facility as required by the applicable section of the Standards, 

the building should be cited as noncompliant.

An example of an Indoor Housing Facility includes, but is not limited to:

• A climate-controlled shed or barn that has a floor with a continuous 

connection with the walls and a roof and at least one door for entry and exit

3.2.5.1.2 Sheltered Housing

The AWA Regulations define Sheltered Housing as: a housing facility which 

provides the animals at all times with:

1. Shelter, and

2. Protection from the elements, and

3. Protection from temperature extremes

A sheltered housing facility may consist of runs or pens totally enclosed in a barn 

or building, or of connecting inside/outside runs or pens with the inside pens in a 

totally enclosed building.

If a housing facility is capable of meeting all aspects of the definition of a 

“sheltered housing facility,” it is considered a sheltered housing facility. Even if 

walls, large doors, or panels are removed for part of the year, it is still considered 

a sheltered housing facility if it provides the animals at all times with shelter and 

protection from the elements and temperature extremes.

Examples of Sheltered Housing include, but are not limited to:

• A facility consisting of connecting inside/outside pens with the inside pens 

contained in a building

• A facility with primary enclosures entirely enclosed within a building which is 

set on top of the ground and does not have a floor which is continuously 

connected to the walls

• A facility consisting of some enclosures that are fully enclosed within the 

building AND some enclosures that are connecting inside/outside pens

3.2.5.1.3 Outdoor Housing

The AWA Regulations define Outdoor Housing as: any structure, building, land, 

or premise, housing or intended to house animals, which does not meet the 

definition of any other type of housing facility provided in the Regulations, and in 
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which temperatures cannot be controlled within set limits.

Examples of Outdoor Housing Facilities include, but are not limited to:

• A facility with outdoor pens that has an open building-like structure with a 

roof and partial walls over the pens that do not provide protection from 

temperature extremes

• Hutch-like enclosures in a yard with no protective covering

• A chain link enclosure with a dirt floor and one or more dog-house type 

structures for shelter for the animals

• A facility with primary enclosures enclosed within a building without a 

climate-control system or protection from temperature extremes at all times

3.2.5.2. Lids on Self-Feeders

Self-feeders may be used for feeding dry food to dogs and cats. The AWA 

Regulations do not require lids for self-feeders. Rather, food for dogs and cats 

must be uncontaminated, wholesome, palatable, and sufficient in quality and 

quantity to maintain good health. Food receptacles must also protect food from 

rain and snow. If the lack of a lid contributed to poor food quality, the lack of a 

lid may be noted in the citation describing the noncompliance.

3.2.5.3. Perimeter Fence

3.2.5.3.1 Determine if the licensed facility requires a perimeter fence [3.127(d)]

The perimeter fence requirements are:

1. Dangerous animals that require a perimeter fence

• Dangerous animals, such as large felids (e.g., lions, tigers, leopards, cougars, 

ligers, and jaguars), bears, wolves, rhinoceros, elephants and polar bears (See 

Appendix B - Dangerous, Potentially Dangerous, and Special License Animals) 

require a perimeter fence that is:

o Not less than 8 feet high, AND

o 3 feet or more in distance from any enclosure housing animals

NOTE: A facility may submit a written request to AC for approval of a 

perimeter fence that is less than 8 feet high and/or less than 3 feet from an 

animal’s enclosure (variance request).

2. Non-dangerous animals that require a perimeter fence

• Non-dangerous animals (e.g., fox, kangaroo, capybara, and prairie dog) and 

nonhuman primates and marine mammals require a perimeter fence that is:

o Not less than 6 feet high, AND

o 3 feet or more in distance from any enclosure housing animals

NOTE: A facility may submit a written request to AC for approval of a 
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perimeter fence that is less than 6 feet high and/or less than 3 feet from an 

animal’s enclosure (variance request).

3. Situations where regulated facilities are not required to meet the perimeter 

fencing requirements

• Situations where a facility does not require an approved written variance to 

deviate from the perimeter fence requirements are:

o Traveling facilities with appropriate security measures 

o Outdoor housing facilities that:

- House only domesticated farm-type animals (such as cows, goats, 

pigs, sheep, llamas, and alpacas, and any hybrid crosses thereof); 

AND

- Have effective and customary containment and security measures 

(e.g., farm-type pens, barns, and fences)

Note: If you come across other farm animal species that are not listed 

above but may be eligible to deviate from the perimeter fence 

requirements, contact your supervisor for guidance. 

• Animal Care has granted standing approval (i.e., the facility does not need to 

seek a written variance) where alternative security measures contain the 

animals:

o Wild/exotic hoofstock (such as, but not limited to, Brahman/zebu, 

mouflons/urials, vicuñas, guanacos, zebra, camels, warthogs, any species 

of deer, caribou, elk, reindeer, and bison); AND

o Have effective and customary containment and security measures 

NOTE: If you come across a hoofstock species that is not listed above but 

may be eligible to deviate from the perimeter fence requirements, contact 

your supervisor for guidance. 

• Facilities with the following conditions and the facility has obtained written 

approval (variance) from the AWO Director: 

o A primary enclosure made of sturdy, durable materials (concrete, wood, 

glass) that is high enough to restrict entry by animals and people

o A protective natural barrier at an outdoor facility that is high enough to 

restrict entry by animals and people

o Alternative security measures that contain the animals

3.2.5.3.2 Perimeter Fence — Open Gate

During times when a zoo is open to the public, there will usually be an opening in 

the perimeter fence allowing public entry. Most zoos have a ticket booth or 

attendant between that open portion of the perimeter fence and the animal 

enclosures or some other method to assure that the animals are safely 

contained when the zoo is open to the public.
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The mere presence of an open entry gate at a zoo is not a stand-alone 

noncompliance. If after review of the entryway, perimeter fence, and the animal 

enclosures, you have concerns about the containment, especially of dangerous 

animals, you should cite the perimeter fence or contact your supervisor.

As a performance-based Standard, if an incident occurs that involves an open, 

unstaffed perimeter fence gate (escape, injury, death, etc.), the fact that an 

open, unstaffed gate contributed to the incident can be included in the language 

of the citation, which should be cited under the section that caused the incident.

3.2.5.4. Unsafe Facility Conditions

Be alert for unsafe facility conditions:

• If the condition(s) adversely affects the inspector, he/she must leave the 

facility

• If not all the animals are safely contained, the inspector must leave the area 

or facility until it is safe to conduct an inspection

• If the condition(s) is noncompliant with the AWA, cite the noncompliance on 

the Inspection Report. Examples include, but are not limited to:

o Bare wiring

o Electrical wires near water

o Electrical wires within reach of animals

o Unprotected heat lamps

• If the condition(s) is not something within the AWA regulatory requirements,

report the item to the licensee, research facility representative, or an 

authorized representative at the facility. Examples include, but are not 

limited to:

o Locked emergency exits

o Unlocked or unsecured controlled substances

• If you feel that you are being threatened, abused, or harassed:

o Leave the facility (see Workplace Violence in the AC Safety and Health 

Manual), and

o Document what occurred in a memo to your SACS, including who said 

what to whom, when, where, and how, using specific language

If you have additional concerns, contact your SACS and the AC Safety and Health 

Officer. 

Miscellaneous Inspection Guidance

3.2.6.1. Authorized Person Conducting Regulated Activity

An authorized person can represent the licensee during a USDA inspection. 
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Generally, any employee of a licensee (dealer or exhibitor) may conduct sales of 

or exhibit animals owned by that dealer/exhibitor and also may accompany the 

inspector.

An authorized person may not sell or exhibit animals he or she owns unless said 

person has his/her own license. In summary, a licensee (Person A) is not able to 

legally empower someone else (Person B) to conduct regulated activity without a 

license. Hence, Person B may not sell or exhibit his/her own animals under 

Person A’s license at any time.

3.2.6.2. Team Inspections

Under certain circumstances, an inspector, SACS, or Animal Welfare Operations 

leader may request or require a team inspection. A team inspection may include 

an ACI, VMO, and/or a Specialist.

A team inspection is required for:

• Next full inspection of a facility with a Direct veterinary care NCI cited by an 

ACI. The second inspector must be a VMO.

• Possible confiscation

• Facilities where the licensee/registrant has threatened, abused, or harassed 

the inspector

Other possible reasons for conducting a team inspection include, but are not 

limited to:

• Focused inspection follow-up of a Direct veterinary care NCI cited by an ACI

• Multiple indirect veterinary care issues

• ACI has concerns about the program of veterinary care

• Multiple noncompliances

• Repeat noncompliances

• Large facilities or complex inspections

• Facilities with current IES investigations

• Expertise in a particular species needed

• Training

• Complaints, such as multiple complaints against the same facility or the same 

issue at the facility

• Licensee/registrant has a history of appealing NCIs

Be sure all inspectors and Specialists involved are listed in eFile.

3.2.6.3. Field Specialist Consultations

If an inspector has an issue or situation that would benefit from a consult with a 

Field Specialist, the inspector may contact the Field Specialist. The inspector 
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must inform his/her SACS (by email cc or phone) about consulting with the Field 

Specialist.

After the initial consultation with the Field Specialist, the inspector and the SACS 

will determine how further consultation with the Field Specialist should occur, 

i.e., going through the SACS or the inspector contacting the Field Specialist 

directly and copying the SACS on any correspondence.

3.2.6.4. Action to Take on Noncompliant Item Noted While Off Duty

If you are off duty and notice a noncompliance at a licensed facility or find an 

unlicensed exhibitor, you are not required to take any action. However, if you 

choose to take action, suggested actions include:

• Assess the severity of the noncompliance

• If in your territory, return to the facility when on duty and conduct an 

inspection or evaluation of the situation

• If not in your territory, contact your SACS when on duty to determine a 

course of action

• Take appropriate immediate action, if required

If you elect to conduct an inspection or evaluation of the situation:

• Contact your SACS or SOTW for approval prior to initiating an inspection or 

evaluation

• If action was taken, send your SACS:

o A memo documenting the situation and the action taken

o The Inspection Report, if appropriate

3.2.6.4.1 Life-Threatening Situation

If there is a life-threatening situation, such as a dangerous animal escape, then:

1. Leave the area immediately

2. Contact facility personnel/management

3. Call 911, if appropriate

3.2.6.4.2 Non-Life-Threatening Dangerous Situation

If you believe that the noncompliance results in a non-life threatening but 

dangerous situation to the animal or the public, speak to the licensee or an 

authorized representative. If the licensee does not correct the NCI at that time, 

then:

1. Speak to the management of the venue

NOTICE

Remember that you cannot work overtime without your SACS approval.
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2. Call your SACS, the SOTW, or the Animal Care Office's emergency contact 

number and discuss a course of action

Contact local authorities, such as the local police or animal control officer, if 

appropriate, e.g., a non-regulated species is involved.

3.2.6.4.3 No Immediate Danger

If you believe that the noncompliance results in no immediate danger to the 

animal or the public, you may choose to:

• Speak to the licensee or authorized representative, or

• Take no action at that time
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3.3. Completing the Inspection Report

General Information

The inspector must complete an official Inspection Report as soon as possible at 

the end of the inspection. (See Notice Box below). Remember that Inspection 

Reports with a Direct NCI must be completed and delivered to the 

licensee/registrant immediately after the inspection. The Inspection Report 

should follow the format of the Inspection Report template in eFile.

For information and instruction on how to plan an inspection, enter data, and 

finalize an Inspection Report in eFile, refer to the training material provided to 

you and contact your SACS if you need assistance.

The Inspection Report must contain the following general information entered 

automatically by eFile:

• Business name

• Customer ID

• Date of inspection

• Licensee, registrant, or applicant’s name as listed on Application for License 

or Registration

• Mailing address as listed on Application for License or Registration

• Site name, if applicable

• Site number or TRA (Traveling on the Road) (see Traveling (TRA) Site) as 

assigned by eFile. Make sure that you are in the correct site, and ensure you 

do not enter an inspection into an inactivate site

• USDA license or registration number (except for prelicense inspections)

If any of the above information is incorrect in eFile due to a data entry error, 

such as a misspelled name or transposed address numbers, contact Program 

Support to have the information corrected before you complete the Inspection 

Report.

NOTICE

Inspection Reports are to be finalized in eFile, delivered in person, or sent to 

the licensee or registrant, within 5 business days of the date of the 

inspection. 

If an Inspection Report has a correction deadline that is less than 5 business 

days, the licensee or registrant must receive the Inspection Report prior to 

the earliest deadline. Exceptions to the 5 day or earliest deadline delivery 

must be pre-approved by a SACS.
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Changes in Business Information

Licensees

If you arrive at a facility that holds a current 3 year license and find that there has 

been a change of ownership, location, activities, or animals as described in 

2.1(b)(2)(i) and (ii) and the licensee did not notify AC at least 90 days prior to the 

change and they are operating under new circumstances, you should:

• Conduct an inspection of the animals 

• Cite the licensee for failure to notify AC of the change in business status 

[2.1(b)(1)]

• Contact your SACS to discuss any further citations

Registrants

If you arrive at a facility and find that there has been as change in name, address, 

ownership, or change in operations affecting its status and the registrant did not 

notify AC within 10 days of the change, you should:

• Conduct an inspection

• Determine whether the change affects the status of the registrant and if so:

o Cite the registrant for failure to notify AC of the change in business status 

[2.27(a), 2.30(c)(1)]

o Contact your SACS to discuss any further citations

Action to Take When a Person, Facility, or Site is NOT in the 

eFile Database

If the person, facility, or site is not in the eFile database:

• If you have internet access:

o After the inspection, contact an Inspection and Licensing Assistant (ILA)

or the Program Coordinator

o Provide the ILA/Program Coordinator the following information:

- Licensee/registrant/applicant/owner’s full name, if applicable

- CID Number, if applicable

- Complete mailing or business address, if needed

- Complete site address, if adding a new site

- County, if known

- Business telephone number, including area code

o Obtain the customer number, if available

o After the ILA/Program Coordinator has updated eFile, enter the 
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Inspection Report into eFile

o After you have reviewed the inspection findings with the licensee/ 

registrant/applicant/owner, and checked the Inspection Report for 

accuracy, finalize the report in eFile before delivering a copy to the 

licensee/registrant/applicant/owner

• If you do not have internet access:

o Complete the Inspection Report using the Microsoft Word Inspection 

Report Template and follow the procedures for Handwritten Inspection 

Reports in Chapter 2.

Traveling (TRA) Site

A traveling site is a temporary animal location, housing, or exhibit area, such as:

• A city where the licensee is performing

• An airport

• An auction market

On the Inspection Report:

1. Make sure that you use the “traveling-on-the-road” (TRA) site designation in 

eFile

o If the licensee does not have a TRA site already in eFile, follow the 

procedures for Action to Take When a Person, Facility, or Site is not in the 

eFile Database

o If the licensee has more than one TRA site, use the correct TRA site if it is 

in eFile

2. Add the exact location of the inspection, such as address, name of the mall, 

building, or fairground, and always include the city and State, in the narrative 

section of the Inspection Report

3. Add the name of the Unit (e.g., Red Unit, Green Unit), if applicable, in the 

narrative section of the Inspection Report

Type of Inspection

The Inspection Report must specify the type of inspection conducted. Enter the 

type of inspection into the eFile Inspection Report template.

The types of inspections are:

• Attempted – situation where an authorized person was not available to 

accompany the inspector. No inspection was conducted.

• Routine – normal periodic, unannounced inspection including:

o Complete inspection of the facility

o New site or additional site inspection for registrants (preapproval of new 
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site not required) 

o A complete inspection to follow up on a public complaint involving animal 

welfare

o An inspection to determine whether unlicensed activity may be ongoing

o Inspection to lift a suspension if required pursuant to a Consent Decision 

or Decision and Order. (Note - This may be a scheduled/announced 

inspection. Consult Regulatory Support Staff.)

• Focused – unannounced inspection including:

o Reinspection for Direct NCIs

o Reinspection for a specific NCI or NCIs cited on the previous inspection

o Partial inspection of the facility, such as animals only or records only

o A partial inspection to follow up on a public complaint concerning animal 

welfare

• Pre-license – inspection to determine compliances with the AWA Regulations 

and Standards prior to issuance of a USDA license. 

• Re-license – inspection to determine compliances with the AWA Regulations 

and Standards prior to issuance of a new USDA license

• New Site – For licensees only - Inspection to determine compliance with the 

AWA Regulations and Standards prior to the use of a new facility site

Inspection Report Narrative

Refer to Inspection Findings in Chapter 2 for instructions on documenting 

inspection findings in the narrative section of the Inspection Report.

Examples of Citations

The following pages show examples of noncompliance citations. Develop a 

consistent method of writing citations.
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EXAMPLE Standard: SECTION 3.1(a) HOUSING FACILITIES, GENERAL

Noncompliance: The roof in the southeast corner of the kennel 

building is falling in due to rotting wood. Pieces of wood from the 

roof have fallen into the pen below that houses three adult dogs.

Why a noncompliance: Housing facilities must be kept in good 

repair, and the kennel building is not in good repair. The falling 

roofing material and wood beams could injure the dogs and result 

in the dogs being exposed to rain and other weather conditions.

How to comply: The roof must be kept in good repair. 

Maintenance problems need to be identified and fixed in a timely 

matter to keep the facilities in good repair and protect the animals 

from injury.

Correction date: Correct by (date).

EXAMPLE Standard: SECTION 3.83 WATERING

Noncompliance: The water receptacle in the enclosure housing ten 

adult macaques has a layer of debris and scum floating on the top 

of the water and a thick layer of algae along the sides.

Why a noncompliance: Nonhuman primates must be provided 

with potable water and water receptacles must be kept clean and 

free of contamination. The presence of debris, scum, and algae is 

an indicator of contamination of the water which can cause illness 

in the animals.

How to comply: All water receptacles should be cleaned and 

sanitized at least once every two weeks, or more often if 

necessary, to keep them clean and free from contamination such 

as dirt, debris, scum, or algae.

Correction date: Correct by (date). 

EXAMPLE Standard: SECTION 3.104(b)(1)(i) SPACE REQUIREMENTS

Noncompliance: Two beluga whales are housed in a pool that only 

provides a Minimum Horizontal Distance (MHD) of 25 feet.

Why a noncompliance: Two beluga whales must be housed in a 

pool to have an MHD of 28 feet and the pool the whales are 

housed in only provides an MHD of 25 feet.

How to comply: Measures must be taken to provide the required 

MHD for the whales.

Correction date: Correct by (date).
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EXAMPLE Standard: Section 3.125(a) FACILITIES, GENERAL

Noncompliance: The enclosure housing three adult tigers has a 

wire panel next to the den which has a broken wire. The ends of 

the broken wire have sharp edges and are protruding into the 

enclosure.

Why a noncompliance: Housing facilities must be maintained in 

good repair to protect the animals from injury and contain the 

animals. The tiger enclosure is not being kept in good repair which 

could result in the tigers being injured by the sharp points on the 

wire.

How to comply: The wire should be repaired or replaced. 

Maintenance problems must be identified and fixed in a timely 

manner to keep the facilities in good repair and protect the 

animals from injury.

Correction date: Correct by (date).

EXAMPLE Multiple Sections and Multiple Species: If an NCI involves multiple 

sections of Regulations/Standards and multiple species, each 

section of the Regulation/Standard must be cited separately.

For example: A food storage room used to store food for guinea 

pigs, rabbits, nonhuman primates, and wild/exotic animals is 

cluttered, dirty, and has broken bags with food spilling on the 

floor, and the unopened bags of nonhuman primate food are 

stored directly on the floor and up against the walls.

Sections 3.25(c), 3.50(c), 3.75(e), and 3.125(c) –STORAGE OF

FOOD would be in noncompliance. Each of these sections should 

be cited for the species affected.

EXAMPLE Multiple Noncompliances under one Section and Subsection: If 

multiple noncompliances involve one section and subsection of 

the Regulations/Standards, these NCIs may be grouped together.

For example, for camels in a petting zoo:

The roof of the barn is in disrepair and has an opening/hole which 

allows rain and snow to fall into the pens.

The partition between the camel pen and the food storage area 

has numerous holes allowing the camel access to the stored food.

The front gate of the outdoor pen has a broken hinge and does not 

close properly.

SECTION 3.125(a)–STRUCTURAL STRENGTH would be the 

noncompliance and all three items could be cited together.
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EXAMPLE Multiple Noncompliances under the Same Section but Different 

Subsections: If multiple noncompliances involve the same section 

but different subsections, each NCI must be cited separately.

For example, for nonhuman primates: There are multiple NCIs of 

SECTION 3.80 PRIMARY ENCLOSURES–General Requirements

SECTION 3.80(a)(2)(i)–A pen housing four spider monkeys has 

broken wire mesh flooring in the right rear corner with sharp wire 

ends sticking up into the pen.

SECTION 3.80(a)(2)(vii)–There is no shade area in the outdoor 

nonhuman primate exhibit, and it is summer with ambient 

temperatures over 100°F.

SECTION 3.80(a)(2)(ix)–A pen housing four baboons has wooden 

walls with all the paint scratched off so that the walls can no 

longer be properly cleaned and sanitized.

Each of these should be a separate citation.

Information Inspectors Should Not Include in the Narrative

The narrative section should not contain:

• Administrative messages to the Animal Care offices or staff

• Animal inventory

• Comments on public complaints

• Date of last inspection

• Personal comments about the facility

• Personal or proprietary information, such as:

o Addresses, other than the licensee/research facility mailing and/or 

business address

o Driver’s license numbers

o Names of animal handlers

o Names of buyers of animals

o Name(s) of person(s) accompanying you on the inspection, except for 

other AC personnel

o Names of principle investigators or research facility personnel

o Names of sellers of animals

o Social security numbers

o Sources of animals

o Telephone numbers, other than your contact information, if applicable
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• Recommended enforcement action

Repeat Noncompliant Item Identified

Refer to Repeat NCI in Chapter 2 for information on Repeat noncompliant items.

Direct Noncompliant Item Identified

Refer to “Direct” NCI Identified in Chapter 2 for information on Direct 

noncompliant items.

Critical Noncompliant Item Identified

Refer to “Critical” NCI Identified in Chapter 2 for information on Critical 

noncompliant items.

Noncompliant Item with Correction Time Remaining

3.3.12.1. Focused Inspection

If you are conducting a “focused” inspection, such as follow up on a Direct or 

Repeat NCI, and there are previously identified uncorrected NCIs that still have 

correction time remaining, do not re-cite or mention these NCIs on the 

Inspection Report. These are not repeat NCIs. Be sure to specify that this was a 

focused inspection in the Inspection Report inspection type.

3.3.12.2. Full Inspection

If you are conducting a full inspection and there are previously identified 

uncorrected NCIs that still have correction time remaining, do not re-cite these 

NCIs. Note on the Inspection Report that the NCIs have not been corrected, but 

that the correction date has not passed. These are not repeat NCIs.

No Regulated Animals Present

Even though there may be no regulated animals present at a facility, an 

inspection may still be conducted.

Factors to consider when deciding whether to inspect a facility include, but are 

not limited to:

• Are there areas of the facility that you have never inspected before, e.g., a 

NOTICE

Remember that the Inspection Report may be used by our Office of the 

General Counsel (OGC) as evidence in a court proceeding. The Inspection 

Report is also available to the public through a Freedom of Information Act 

request or viewed via the Internet at the Animal Care website.
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new building?

• Are there records to inspect?

• Are there transportation vehicles to inspect?

• Does this facility have a history of noncompliance?

• Even though there are no animals currently at the facility, do regulated 

animals go in and out of the facility, such as traveling animal acts?

• Is the facility due for an inspection?

• Is this a new facility added to your territory?

• Is this an active research registrant that has not been inspected this fiscal 

year?

After using your best judgment and determining that there is nothing to inspect, 

you may choose not to conduct an inspection.

If you conduct an inspection:

• Classify the inspection as “Routine”

• Only cite NCIs (or document as a teachable moment, as appropriate) found 

during the inspection if the area with the noncompliance:

o is currently in use, but no animals are there on the day of your 

inspection, or

o is ready for use

• For the correction date, use the following or a similar statement: “Correct 

before being used for animals regulated by the Animal Welfare Act.”

• If a partial inspection, state which areas were inspected, such as records 

and/or specific buildings

• State in the narrative, “No regulated animals present at this time.”

If you do not conduct an inspection:

• Do not complete an Inspection Report

• Send a memo to your SACS explaining why you did not conduct an inspection

Non-regulated Animals

Non-regulated animals should not be inspected or mentioned on the Inspection 

Report unless there is potential for a negative effect on the health or well-being 

of the regulated animal(s).
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EXAMPLE Examples of a potential negative effect are:

A horse is chasing a deer in a pasture on public display and causing 

the deer stress or injury

Rats of the genus Rattus bred for use in research with an infectious 

disease are housed in the same room with rabbits

The number of non-regulated animals is so large that the current 

staffing is inadequate to properly care for the regulated animals

Correction Date

A correction date is the time period in which a noncompliant item must be 

corrected. Include an actual date with the citation; do not use the term 

“immediately.”

A correction date should be:

• Appropriate to the severity of the NCI

• Determined with the concurrence of the licensee/registrant or authorized 

representative, if appropriate

• Realistic as to what the facility can accomplish

A correction date is given for:

• Newly identified “Direct” NCIs. Give these NCIs a short correction period, 

e.g., by close of business on (date), within 72 hours, within 5 days. The 

correction date for direct NCIs should never exceed 14 days.

• Newly identified NCIs other than “Direct” NCIs. If reasonable with respect to 

the health and well-being of the animals involved, an inspector may allow up 

to 1 year for some corrections. Some examples of corrections that may 

warrant a year- long correction period are:

o Perimeter fence replacement

o Full replacement of animal enclosures

o Instituting a new protocol form

• For NCIs with long correction dates, the inspector should periodically check 

on progress with the licensee/registrant, either via a telephone call or a 

courtesy visit

NOTICE

If the Inspection Report is being sent by certified mail, allow for the mailing 

time when setting the correction date.
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For NCIs corrected during to the inspection:

• The correction should read “Corrected during the inspection.” and do not 

give a correction date.

A correction date is not given for:

• Airline transportation noncompliances

• NCIs identified on a Prelicense Inspection

• NCIs cited on a New Site approval inspection, except for a Direct NCI

• Repeat noncompliant items

3.3.15.1. Extension of Correction Date

An extension is an additional amount of time to correct a noncompliant item 

granted through Animal Welfare Operations leadership.

A licensee/registrant may request an extension if he/she will not be able to 

correct the NCI by the correction date.

At the time of the inspection, if a licensee/registrant anticipates that an 

extension will be needed because you cannot agree on a correction date or the 

licensee/registrant wants more than one year, explain to him/her how to 

request an extension.

An extension request, whether anticipated or unexpected, must be:

1. In writing

2. Appropriate, i.e., only for an NCI other than a direct NCI (e.g., one related to 

facility maintenance)

3. Specific as to the reason/justification for the request

EXAMPLES • Unexpected delays during the correction process, such as 

budget or severe weather delays

• Unforeseen special circumstances that prevent 

completion, such as death or serious illness in the family

4. Sent to the Fort Collins Animal Care office 

5. Received by the Animal Care office prior to the original correction date

NOTICE

Reinspect for correction of a “Direct” noncompliant item no later than 14

days after the date of inspection.

NOTICE

Extensions are for special circumstances. Do not suggest an extension to the 

licensee for correction of routine noncompliant items.
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3.3.15.2. Processing of the Extension of Correction Date Request

Take the following actions to process the extension of the correction date 

request:

1. The Animal Care office will send the extension request to the appropriate 

SACS

2. SACS will review and discuss with the inspector, if necessary

3. SACS will write the letter informing the licensee/registrant whether or not 

the extension was granted

4. SACS will upload the letter into the licensee/registrant’s file in eFile

5. SACS will email the letter to the licensee/registrant if email is available, OR

6. SACS will send the letter to Program Support at the Fort Collins Animal Care

office and Program Support will send the letter to the licensee/registrant

Prior to Printing the Final Inspection Report

To make the Inspection Report as accurate as possible, ensure that:

• You are entering the inspection:

o Under the correct licensee/registrant

o Under the correct certificate number

o In the correct site

• All information is entered into the database correctly, such as:

o Inspection type

o Name and address of person on the Inspection Report

• All information in the narrative is correct, such as:

o Citation section and subsections

o Buildings/locations inspected, if appropriate

o Location of inspection of a TRA site

o Names of elephants inspected

• The narrative section uses the appropriate wording to describe the problem

• Repeat NCIs are properly designated

NOTICE

If the incorrect section or subsection was cited on the previous inspection, 

cite the correct section and subsection and add: “Cited incorrectly under 

(section/subsection #) on (date) inspection.”
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• Check spelling and grammar and review a draft copy of the Inspection Report 

with the licensee/registrant/facility representative

• Make the appropriate changes, if necessary, and print the Inspection Report 

for the L/R or applicant

BE SURE TO FINALIZE THE INSPECTION REPORT.

Finalizing the Inspection Report

After you have (1) reviewed the inspection findings with the licensee/ 

registrant/applicant, (2) given the facility representative the opportunity to 

provide additional information pertinent to the findings, and (3) checked the 

Inspection Report for accuracy, finalize the report before delivering a copy to the 

licensee/registrant/applicant. (For additional information and instruction, refer 

to the eFile Guidance.)

Handwritten Inspection Reports

There are certain situations where the inspector may choose to, or must, hand 

write the Inspection Report, including but not limited to:

• Computer failure

• Printer failure

• Unique situations which may arise where the use of the computer is not 

feasible

If you hand write an Inspection Report, use the blank pre-printed Inspection 

Report form. Always have a supply of blank pre-printed Inspection Reports, 

either with you, or in the government vehicle.

When using the pre-printed Inspection Report:

• Hand write all information legibly and neatly

• Use black or blue ink

If you want to give the licensee/registrant/facility representative a copy of the 

handwritten Inspection Report at the time of the inspection, either make a 

photocopy, or complete two reports.

REMEMBER:

• You must enter the handwritten Inspection Report into the eFile database as 

soon as possible

• The narrative entered into the eFile database must be identical to the 

NOTICE

You do not have to completely finalize an Inspection Report for a specific site 

to do an Inspection Report for another site of the same licensee or registrant.
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handwritten Inspection Report

• Do not put a statement that this is electronic or transcribed version of the 

original Inspection Report

If the licensee/registrant does have a copy of the handwritten Inspection Report:

• Only send a copy of the eFile Inspection Report to the licensee/registrant if it 

is not exactly the same as the handwritten copy. For example, any of the 

dates do not match. 

• Then destroy the original Inspection report

If the licensee/registrant does not have a copy of the handwritten Inspection 

Report:

• Send a copy of the eFile Inspection Report to the licensee/registrant by email 

or certified, return receipt mail, and

• Then destroy the original copy

In the case of a printer failure, send a copy of the report to the licensee/ 

registrant/applicant by email or certified, return receipt mail when the printer is 

repaired.

Mistakes on the Inspection Report

Read the Inspection Report carefully before printing and finalizing to ensure that 

all information and spelling are correct.

Incorrect customer ID, date of inspection, site name (001, TRA), USDA license or 

registration number, requires rescinding the Inspection Report, correcting the 

error, and sending the licensee/registrant an amended report with an Amended 

Report Letter.

3.3.19.1. Major Errors

If a major error is noted on the Inspection Report after the final copy has been 

printed or the Inspection Report has been finalized, it must be corrected.

Major errors include, but are not limited to:

• Correction date given for a repeat noncompliance

• Correction date(s) omitted

• Exit interview statement not included

• Incorrect citation

• Incorrect inspection type

• Factual errors

• Wrong site
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3.3.19.2. Mistakes Noted by the Animal Care Office

If Program Support or Animal Welfare Operations leadership discovers a mistake 

on an Inspection Report:

1. The inspector and the SACS will be notified

2. The inspector must correct the Inspection Report following the procedure 

outlined in Correcting or Amending the Inspection Report

3. The inspector must deliver the amended Inspection Report to the licensee in 

person or send by email or certified, return receipt mail within 2 weeks

Correcting or Amending the Inspection Report

No pen and ink changes may be made to the Inspection Report. 

If a major error(s) is noted after the Inspection Report has been finalized, and a 

copy of the Inspection Report has not been given to the licensee/registrant/ 

facility representative:

1. Contact your SACS or SOTW if your SACS is not available to have the 

Inspection Report reset to draft

2. Correct the draft Inspection Report

3. Provide a copy of the corrected Inspection Report and Animal Inventory to 

the licensee/registrant/facility representative through the usual delivery 

methods

If a major error(s) is noted after the Inspection Report has been finalized and a 

copy of the Inspection Report has been given to the licensee/registrant/facility 

representative:

1. Notify your SACS to have the original Inspection Report rescinded

2. Enter a new Inspection Report into eFile

3. Provide a copy of the corrected Inspection Report, Animal Inventory, AND 

the Amended Report Letter to the licensee/registrant/facility representative 

through the usual delivery methods

The new Inspection Report must:

1. Be dated the date that the actual inspection was conducted in “Inspection 

Date”

2. Be dated at the bottom the date that the amended Inspection Report was:

o “Prepared” by you, and

o Sent to the licensee/registrant

NOTICE

Spelling or grammatical errors are not considered major errors.
--- Animal Care Inspection Guide ---

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3. Correct the major mistake for which the amended Inspection Report is being 

generated

4. Cite the noncompliances that were correct on the original Inspection Report. 

These noncompliances must be identical to the citations that were on the 

original Inspection Report. 

Do not put a statement or any reference on the Inspection Report that this was 

an amended Inspection Report.

Inspection Appeals Process [2.13]

If the licensee/registrant has a concern about any findings on the Inspection 

Report, he/she may use the inspection appeals process to resolve the dispute.

3.3.21.1. Prior to Finalizing the Inspection Report

If a licensee/registrant/facility representative has questions or concerns about a 

noncompliant item(s) cited on the Inspection Report, the inspector should 

explain why the noncompliance was cited and give the facility representative the 

opportunity to provide additional information pertinent to the findings at the 

exit interview (see Exit Interview in Chapter 2). If the concern is resolved, 

change the citation. If the concern cannot be resolved:

• Inform the licensee/registrant/facility representative of the next step in the 

appeals process

• Give the licensee/registrant/facility representative a copy of the Appeals 

Process Factsheet

If there was an unresolved disputed noncompliance:

• Photograph any NCI that the licensee/registrant is going to appeal or likely to 

appeal (see Inspection Photographs in Chapter 2)

• Finalize the Inspection Report

• Inform your SACS that there may be an appeal of a noncompliance item(s) 

cited on the Inspection Report

3.3.21.2. After Finalizing the Inspection Report

If a licensee/registrant/facility representative has questions or concerns about a 

noncompliant item(s) cited on the Inspection Report, meet with the licensee/ 

registrant/facility representative, if requested, to discuss the noncompliance.

If you and the licensee/registrant/facility representative resolve the 

disagreement on the noncompliance:

NOTICE

The ‘prepared by’ and ‘signed by’ dates do not have to be the same.
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• Generate an amended Inspection Report and inform your SACS of the 

resolution

• Give or send (by an acceptable method) a copy of the Inspection Report, 

Animal Inventory, and the Amended Report Letter to the licensee/registrant

If the dispute cannot be resolved:

• Inform the licensee/registrant/facility representative of the next step in the 

appeals process

• Give the licensee/registrant/facility representative a copy of the Appeals

Process Factsheet

• Photograph any NCI that the licensee/registrant is going to appeal or likely to 

appeal, if possible

• Inform your SACS that there may be an appeal of a noncompliance item(s) 

cited on the Inspection Report

If the licensee/registrant’s appeal of a noncompliance is determined to be valid, 

i.e., a citation is modified or deleted, the original Inspection Report will be 

rescinded in eFile. Program Support, in the appropriate Animal Care office, will 

generate a new draft Inspection Report for the inspector to amend. The 

inspector amends the Inspection Report and delivers the Inspection Report, 

Animal Inventory, and the Amended Inspection Letter to the licensee/ 

registrant/facility representative by an acceptable delivery method. 

If the licensee/registrant’s appeal of a noncompliance is determined to be

invalid, the appeals team assigned to the matter will write a letter to the 

licensee/registrant/facility representative informing him/her of the decision. 

The inspector and SACS will receive a copy of the letter from Program Support. 

NOTICE

Inspection appeals should not delay reinspection of Direct noncompliances or 

interfere with efforts to ensure that the immediate welfare needs of the 

animals are met.
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3.4. Safety and Ethics Issues

Bribery Reporting Procedures—Inspector’s Responsibility

If you are offered a bribe, or perceive that you are being offered a bribe, refuse 

the bribe, and report it immediately to the Office of the Inspector General (OIG). 

Do not report the bribe to your supervisor.

It is your duty to report being offered a bribe, or if you perceive that you are 

being offered a bribe.

Follow these steps if you are offered a bribe, or perceive that you are being 

offered a bribe:

1. Do not take the bribe. Say, “I cannot do that.” Do not discuss the bribe offer 

any further, and do not tell the person who offered it that you are going to 

report it to law enforcement or other authorities.

If you do not believe that you are in danger, then assess the situation and use 

your judgment as to what to do, since you do not want the person to think that 

you are going to report the incident to the authorities. Some possible courses of 

action include, but are not limited to:

1. Give the person a plausible excuse and leave the facility

2. Complete the inspection or exit interview quickly, but not suspiciously so

3. Complete the inspection, then tell the person that you are going to complete 

the Inspection Report off site

4. At the first practical moment after you are out of sight and earshot of the 

person who made the offer, and as soon as privacy permits, telephone OIG

using one of the following phone numbers:

o (202) 720-7257 – 24-hour direct line to OIG, Washington, DC, for 

reporting threats, assaults, and bribery attempts, or

o (800) 424-9121 – OIG Hotline for reporting fraud, waste, and abuse, or

o (202) 690-1622 – Commercial hotline

Note: Collect calls are accepted.

5. Follow the instructions given to you by the OIG Special Agent. An OIG Special 

Agent will respond to your telephone call. Based on information that you 

provide, OIG Agents will evaluate the alleged bribery attempt to determine 

the appropriate investigative action. OIG needs your full cooperation.

SAFETY

If you believe that you are in any danger at this time, leave the facility as 

quickly and safely as possible.
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6. Do not report the bribery attempt to your supervisor or discuss it with 

anyone else unless instructed to do so by an OIG Special Agent. Any 

discussions could compromise the investigation. OIG will ensure that 

appropriate supervisory personnel are notified in a manner which will not 

prejudice the investigation.

7. Any subsequent contacts or communication between you and the person 

who offered the bribe will be controlled and monitored by the OIG

o Do not be afraid to cooperate with investigators. Even though you would 

not accept a bribe, it is your duty to report such matters and to 

cooperate fully with investigators to prevent further bribery attempts to 

you or other USDA employees.

Bribery Reporting Procedures—Supervisor’s Responsibility

If an employee reports an offer or a perceived offer of a bribe to you:

Instruct the employee to call OIG immediately, if he/she has not already done so

1. Do not discuss the bribery attempt any further with anyone, including the 

employee

2. Do not attempt to investigate the incident

Gifts from Licensee/Registrant

Do not accept any “gifts” from licensees or registrants greater than the value of 

a soft drink or cup of coffee. You do not want any perception of impropriety.

Interference with the Inspection

A licensee, applicant, research facility representative, or other person must not 

interfere with, threaten, abuse, or harass any APHIS official in the course of 

carrying out his/her duties.

If you believe that any person at the facility is interfering with the inspection 

process:

• Tell him/her to stop if it is safe to do so

• If the behavior continues or you feel unsafe, leave the facility

• Contact your SACS

• Document what occurred in a memo to your SACS, including who said what 

to whom, when, where, and how, using specific language

For more detailed information on Interference, see Chapter 2 and the AC Field 

Safety and Health Manual.
--- Animal Care Inspection Guide ---

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Specific Types of Inspections

Contents

4.1. Airport Inspection 4-4

Badging Credentials 4-4

Conducting an Airport Inspection 4-4

Inspection Reports 4-5

Photographs 4-5

4.2. Animal Rides 4-6

Criteria 4-6

Conducting the Inspection 4-6

Inspection Reports 4-7

4.3. Attempted Inspections 4-8

Attempted Inspection General Procedures 4-8

Courtesy Visits 4-10

Conducting an Unannounced Inspection after the Courtesy Visit 4-11

Compliance Support Staff (CSS) 4-12

Regulatory Support Staff (RSS) 4-12

Additional Attempted Inspection Guidance 4-12

The Facility Contact Worksheet 4-14

Optimal Hours 4-14

Handy Tips 4-14

4.4. Auction Market Inspection 4-16

Criteria 4-16

Animals Requiring Veterinary Care 4-17

Records 4-17

4.5. Barrier Facility Inspection 4-19

Criteria 4-19

Alternative Methods of Inspection 4-20

4.6. Change in Class of License Inspection 4-21

Criteria 4-21

Conducting the Inspection 4-22

4.7. Complaint Inspection 4-23

Sources of Information 4-23

Receipt of the Complaint Information 4-23

Responding to the Complaint 4-24

Information Follow-Up 4-24

4.8. Courtesy Visits 4-25

General Information 4-25

Documenting a Courtesy Visit 4-25

Conducting the Courtesy Visit 4-27

4.9. Dead Animal/Parts or Serum/Blood Dealer Inspection 4-29
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Dead Animal/Parts 4-29

Blood and Serum Collection 4-29

4.10. Dogs and Cats in Residence Inspection 4-31

4.11. Domestic Hoofstock Inspection 4-33

Domestic Hoofstock Housed in an Agricultural Setting 4-33

Domestic Hoofstock Housed in a Non-Agricultural Setting 4-33

4.12. Drive-through Zoo/Park Inspection 4-34

Conducting the Inspection 4-34

Animal Inspection 4-35

Handling 4-35

Public Feeding 4-36

Facility Inspection 4-37

4.13. Lion and Tiger Enclosure Inspection 4-41

Evaluating Enclosures 4-41

4.14. Marine Mammal Facility Inspections 4-43

Conducting the Inspection 4-43

Veterinary Care 4-43

Space 4-44

Feeding 4-45

Water Quality 4-46

Shelter and Shade 4-47

Public Barriers 4-48

Separation 4-49

Employees 4-49

Recordkeeping 4-50

Swim-with-the-dolphin (SWTD)/Interactive Programs 4-50

4.15. New Site Approval Inspection 4-51

Addition of a Site 4-51

Site Inspection 4-51

4.16. Pet Store Inspection 4-53

Criteria 4-53

Record Requirements 4-54

Identification 4-54

4.17. Petting Zoo Inspection 4-55

Inspection Procedures 4-55

Traveling Petting Zoo Itinerary 4-57

Animal Information 4-57

Exhibition and Transport Information: 4-58

4.18. Photo Shoot Inspection 4-59

Types of Photo Shoots 4-59

Conducting the Inspection 4-60

4.19. Prelicense Inspection Process 4-62

Initial Contact with the Applicant 4-62

First Prelicense Inspection 4-63

Second Prelicense Inspection 4-65

Third Prelicense Inspection 4-66
--- Animal Care Inspection Guide ---

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Completing the Inspection Report 4-66

Photographs 4-69

Relicensing 4-69

PL Inspection Process Reminders 4-71

4.20. Search Inspection 4-72

Subjects of Searches 4-72

Sources of Information 4-72

Information Follow-Up 4-73

Preparing for the Search 4-74

Post Search Procedures 4-76

Follow-Up Procedure 4-76

On the Road Inspection 4-77

4.21. Traveling Exhibitor Inspection 4-78

Home Site Inspection 4-78

General Information 4-78

Admission to the Venue 4-79

Conducting the Inspection 4-80

Animals in Transit 4-84

Animal Races 4-84

Animal Rides 4-85

Circus and Performing Animal Inspections 4-85

Petting Zoos 4-87

Photo Shoots 4-87

Inspection Reports 4-87

Itinerary 4-87

4.22. Wild/Exotic Animal Auction Inspection 4-89

Licensing Requirements 4-89

Regulatory Responsibilities 4-90

Inspection Procedures 4-90

DISCLAIMER

The Animal Welfare Inspection Guide is intended to be a reference document to assist the 

inspector. The Inspection Guide does not supersede the Animal Welfare Act (AWA), the AWA 

Regulations and Standards, AC policies and other guidance, the Required Inspection 

Procedures, standard procedures, or the inspector’s professional judgment. All inspection 

decisions must be justified by applicable sections of the AWA and/or the AWA Regulations 

and Standards.
--- Animal Care Inspection Guide ---

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4.1. Airport Inspection

Registered Transporters or Intermediate Handlers operating at an airport must

meet all applicable transportation Regulations and Standards.

Badging Credentials

Some airports, especially large airports, may require that you obtain a badge to 

access the airport property and facilities. Prior to conducting your first 

inspection, you should check with the airport authorities to determine if a badge 

is needed.

If there is a fee for the badge, the fee may be charged to your Purchase 

MasterCard. 

Conducting an Airport Inspection

When conducting an inspection, some additional procedures include, but are not 

limited to:

• Follow all the safety rules

• Be accompanied by an airline representative unless you are approved by the 

airport authorities to be unaccompanied

• Inspect all areas where animals may be housed or transported, including but 

not limited to:

o Ticket counter

o Cargo area

o Baggage area

o Any other areas where animals are held before travel, such as offices and 

live animal rooms 

o Planes on the tarmac if necessary

o Transport vehicles and conveyances used to transport animals to and 

from the planes

• Check for applicable required records, such as:

o Health Certificates [2.77(b), 2.78]

o Consignor information such as from Waybills or other records

o Certifications required for the different species

o COD payment guarantee [2.77]

• If you find an unlicensed dealer, broker, or unregistered transporter:

o Make a copy of the Waybill and any other supportive documentation 

showing regulated activity, and
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o Follow the procedure for a “Search Inspection”

4.1.2.1. Commercial Dog Importations

If an inspector identifies an import shipment that is out of compliance with 

Section 2.150/2.151/2.152, he/she should just:

• Make a copy of the Waybill. Be sure that the Waybill has the name and 

contact information for the importer.

• Send the copy of the Waybill to the Live Dog Import Team (LDI Team) at

ac.dogimport.mailbox@aphis.usda.gov

The issue will be addressed by the LDI Team.

Inspection Reports

4.1.3.1. No NCIs Reports

For an Inspection Report with no noncompliances, the inspector may:

• Complete the IR at the airport and leave a copy with that facility 

representative (signature not required), OR

• Send the IR by regular mail to the airline’s corporate office, OR

• Send the IR to the airline’s corporate office via email. Inspector must obtain 

an email address from the airline facility representative. 

4.1.3.2. Inspection Reports with NCIs

For NCIs cited on an airline Inspection Report:

• Do not give a correction date for any NCIs

• Designate an NCI meeting the criteria for a Direct or Critical as a “Direct” or 

“Critical”

• Do not designate a Repeat NCI as a “Repeat” 

• If applicable, obtain a copy of the appropriate Waybill for each NCI, reference 

the Waybill number in the NCI narrative, and submit with the Inspection 

Report to the AWO Field Office

For delivery of an Inspection Report with noncompliances, the inspector may:

• Complete the IR at the airport and leave a copy with the facility 

representative (preferred), OR

• Email the IR directly to the airline’s corporate office using an email address 

obtained from the facility representative

Photographs

Take photographs of all NCIs cited at commercial airline carrier inspections. 
--- Animal Care Inspection Guide ---

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4.2. Animal Rides

An exhibitor who uses regulated animals to give rides to the public must meet all 

applicable Animal Welfare Act Regulations and Standards.

Criteria

Examples of regulated animals used for rides are:

• Camels

• Elephants

• Llamas

Conducting the Inspection

When inspecting animals used for rides, make sure that the exhibitor meets all 

the applicable Regulations [9 CFR Sections 2.40, 2.50, 2.75, 2.78, 2.80, 2.125, 

2.126, 2.130, 2.131], and all the Standards, including the Transportation 

Standards, for the animals being used.

When conducting your inspection, some suggested areas to pay attention to 

include, but are not limited to:

• Animal’s locomotion, gait, and uniformity of stride

• Animal’s physical condition and behavior

• Appropriateness of the weight load for the animal

• Attentiveness of the handler during the ride, i.e., is the handler distracted in 

some manner and not paying attention to his/her duties

• Availability and frequency of access to drinking water

• Availability of shade or shelter

• Condition of the equipment, i.e., no sharp edges, no broken straps, buckles, 

or fasteners, padding not thin or excessively worn

• Plan to provide veterinary care if an animal is injured away from the home 

facility

• Foot care, especially elephants

• Number of personnel, i.e., are there enough personnel to watch for 

dangerous behaviors from the animals, the riders, and the viewing public

• Perimeter fence and/or barriers between the animals and the general 

viewing public

• Rest for animals between rides and overnight
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• Proper fit of saddles, riding equipment, halters, or restraint devises. Some 

signs of improper fit include:

o Abrasions

o Hair loss

o Irritated skin

o Redness

o Sores

• Training and handling experience of the handlers and employees

• Reluctance of the animal to lead or work

Inspection Reports

For a TRA inspection, follow the guidance in Traveling Exhibitor Inspection –

Inspection Reports.

NOTICE

Animals must be allowed a rest period equal to the amount of time that they 

were giving rides. [2.131(c)(2)]

NOTICE

Put the name of the elephant(s) on the Inspection Report.
--- Animal Care Inspection Guide ---

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4.3. Attempted Inspections

The purpose of this procedure is to standardize attempted inspections by 

utilizing enhanced communication and outreach in an effort to reduce 

attempted inspections. The goal is to use all tools at our disposal in order to 

decrease the number of attempted inspections conducted. This will help to 

ensure the welfare of the animals at our regulated facilities by increasing facility 

access, as well as improve consistency when conducting attempted inspections.

All procedures must be documented on an Attempted Inspection Checklist. 

The checklist must be uploaded into eFile.

Attempted Inspection General Procedures

These procedures will be followed for all attempted inspections regardless of 

repeat status (i.e., first attempted and all repeat attempted inspections):

1. If an authorized person is not present at the facility, every effort should be 

made to contact them at the time of the inspection. This includes, but is not 

limited to:

o Call all numbers previously provided by the licensee/registrant, including 

those in eFile

o If possible, leave a message stating your name, purpose, phone number, 

and request for a return phone call

o Attempt to get the attention of anybody who may be on the property 

(honk horn, ring doorbell, and knock on facility doors that are readily

accessible)

2. If contact is not made by phone:

o wait 30 minutes

o If a facility representative does not arrive at the facility or return your call 

within 30 minutes, continue with the attempted inspection procedures 

listed below, starting with #4 - Prior to leaving the facility

o If the licensee/registrant returns your call during the 30-minute window, 

follow the procedure listed in #3 for when contact is made.

3. If contact is made by phone:

o Determine if an authorized person can be at the facility within 60

minutes

o If not, let them know you will be in contact with them at a later date to 

discuss attempted inspections. Continue with the attempted inspection 

procedures listed below, starting with #4 - Prior to leaving the facility.

o If so, wait up to 60 minutes for the authorized person to arrive and 

conduct an inspection
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o If the authorized person or a facility representative does not arrive within

60 minutes, call them back to check if they are still on their way. Use 

your professional judgment as to how much longer to wait (e.g., If the 

licensee says they will be there in 5-10 minutes, waiting for 5-10 minutes 

more is reasonable). Conduct an inspection when they arrive at the 

facility.

o If they do not show up or are unable to arrive at the facility within a 

reasonable time, continue with the attempted inspection procedures 

listed in #4.

4. Prior to leaving the facility, complete an Attempted Inspection Leave Behind 

Flyer and leave it in a location where it can be easily found. Do not leave the 

flyer in a mailbox.

5. Follow the procedure in Attempted Inspections in Chapter 2 for documenting 

an Attempted Inspection. Designate the attempted as a “repeat,” if

appropriate.

After leaving the facility, the inspector should attempt to contact the 

licensee/registrant up to three times, preferably by phone, and within one week 

of the inspection and:

• When contact is made:

1. The inspector should explain to the licensee or registrant the importance of:

o Conducting an inspection

o Business hours and optimal hours (See Section 4.3.8 Optimal Hours for 

eligibility)

o Facility representatives

o Providing contact information such as cell phone numbers, etc.

The “Script Following an Attempted Inspection” can be used for this 

purpose.

2. The inspector should attempt to identify the reason for the attempted 

inspection and work with the facility to find a solution

3. The inspector will complete or update the “Facility Contact Worksheet” with 

input from the licensee or registrant. This worksheet must be uploaded into 

eFile within five days (See the Facility Contact Worksheet for uploading

instructions).

4. In addition to the above, if this is the facility’s first repeat attempted (Second

consecutive attempted or at least the second attempted inspection in the 

past three years), follow Section 4.3.2 - Courtesy Visit Procedures

• If no contact is made after three tries:

1. The inspector will send the Attempted Inspection Letter and Enclosure by 

regular mail
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2. A copy of this letter should be uploaded into eFile

3. The inspector should wait at least two weeks after sending this letter before 

attempting another inspection

4. If the licensee/registrant contacts you at any time after this letter is sent, the 

inspector will follow the instructions above for when contact is made,

including the Courtesy Visit Procedures, if eligible.

Courtesy Visits

A Courtesy Visit will:

• Allow Animal Care to check on the welfare of the animals at facilities where 

access has been limited

• Allow Animal Care to explain to facilities the importance of conducting

inspections

• Help to improve or establish better working relationships with

licensees/registrants

• Provide an opportunity for Animal Care to work one-on-one with 

licensees/registrants to identify reasons for attempted inspections along with 

possible solutions to prevent future attempted inspections

• Provide Animal Care an opportunity to obtain and document information 

from the licensee/registrant, such as optimal hours, that will help to prevent 

future attempted inspections

• Allow Animal Care a chance to inform the licensee/registrant about other 

resources Animal Care has to help them maintain compliance (e.g., breeder 

resources, species specialists, compliance specialists, etc.)

4.3.2.1. Scheduling a Courtesy Visit

In addition to the Attempted Inspection General Procedures, the following 

procedures should be done for all facilities receiving their first repeat attempted 

(Second consecutive attempted or at least the second attempted inspection in 

three years):

1. The inspector will schedule a courtesy visit with the facility at an agreed upon 

date and time. The courtesy visit should be conducted within two weeks 

from the date ofthe phone call.

2. If the licensee or registrant declines a courtesy visit, the declination should 

be documented on the Attempted Inspection Checklist

3. If a Compliance Specialist (CS) is already involved with the facility, the 

inspector will reach out to the CS prior to conducting the courtesy visit so 

they are aware of the visit
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4.3.2.2. Conducting a Courtesy Visit

A courtesy visit will be offered to all facilities receiving their first repeat

attempted (i.e., two consecutive attempted inspections or at least the second 

attempted inspections in three years)

Courtesy Visit Procedures:

1. A facility walkthrough and records review should be conducted (as you would 

during a routine inspection). Do not document the results of the 

walkthrough or review. If the licensee/registrant wishes, they can take notes 

regarding your findings or suggestions.

2. The following information will be provided to the licensee/registrant during 

the courtesy visit:

A. The PowerPoint “The Animal Welfare Inspection Process and Attempted 

Inspections” will be presented to the licensee

B. The inspector will complete or update a “Facility Contact Worksheet” 

with input from the licensee/registrant. This worksheet must be 

uploaded into eFile within five days (See the Facility Contact Worksheet 

for instructions).

C. The inspector should attempt to identify the reason for the attempted 

inspection and work with the facility to find a solution

D. The inspector should let the licensee or registrant know that the courtesy 

visit will be followed by an unannounced inspection. Do not give them a 

timeframe for this inspection.

E. Stress the importance of making this a successful (non-attempted) 

inspection

F. Leave your business card/contact information and encourage them to 

contact you with questions, schedule changes, changes in optimal hours 

(if eligible), etc.

The courtesy visit should be recorded in eFile as a “courtesy visit to follow-upon 

compliance concerns.” See Section 4.8 “Courtesy Visits” for more information on 

documenting courtesy visits in eFile.

Conducting an Unannounced Inspection after the Courtesy 

Visit

A routine unannounced inspection should be conducted within two months 

after the courtesy visit.

If an inspection is conducted, complete an Inspection Report followingnormal 

procedures.

If this inspection is an attempted inspection:
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• Follow the Attempted Inspection Procedures (not including the courtesy visit)

• Document the attempt on an inspection report, and

• Designate it as a “repeat” (second repeat)

• This facility will be referred to the Compliance Support Staff

Compliance Support Staff (CSS)

If the inspector, after consultation with their SACS, feels that a compliance call or 

visit would help at any step in the Attempted Inspection or Courtesy Visit 

process, they should send a request to the Supervisory Compliance Specialist.

4.3.4.1. Third Attempted Inspection (Second Repeat AI)

The third Attempted Inspection (second repeat) will automatically trigger a 

referral to a CS who will be assigned to work with the facility. The CS will contact

the inspector prior to communicating with the facility. The inspector should let 

the CS know everything they have done to try to work with the facility and 

provide any other information or guidance that might be helpful. The inspector, 

SACS, and CS will determine the best course of action for the CS to take (e.g., 

calling, going on a compliance visit, or riding with the inspector on a 

visit/inspection).

Regulatory Support Staff (RSS)

A facility will be referred to RSS for possible license revocation after the fourth 

Attempted Inspection (third repeat Attempted Inspection).

Additional Attempted Inspection Guidance

To facilitate and build customer relationships with licensees and registrants, 

inspectors must remain aware of varied traditions, religious requirements, 

community culture, and emergency situations that can sometimes affect the 

daily operation of our regulated facilities. 

In an effort to become more customer service oriented, inspectors must be 

courteous, considerate, and demonstrate compassion to the needs and efforts of 

our licensees and registrants in these situations. Remaining cognizant of 

traditions, religious requirements, and emergency situations will help to build 

trust and improve working relationships with our licensees/registrants. This will 

help to ensure that our suggestions, guidance, teachable moments, and talking 

points are accepted and implemented to improve the health and well-being of all 

regulated animals.

4.3.6.1. Common Amish Holidays

The following are common Amish holidays not normally observed by federal 

employees. Work with the individual Amish communities to develop a plan for 
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completing an inspection around these days.

• Old Christmas (6 January)

• Good Friday & Easter Monday (Friday & Monday prior to and following

Easter)

• Ascension Day (40thDay after Easter Sunday)

• Pentecost Monday (7th week after Easter)

• St. Michael’s Day/Michaelmas (11 October)

• Second Christmas (26 December)

• New Year’s Eve (31 December)

• Weddings are typically held on Tuesdays or Thursdays in the fall/harvest 

seasonthrough winter

4.3.6.2. Choosing Not to Cite an Attempted Inspection at a Facility

In some circumstances, when an inspector arrives at a facility, it may be 

determined that it is not appropriate to conduct an inspection (see examples 

below). If an inspector is unsure whether or not to conduct an inspection, or if 

this is a recurring issue at this facility, the inspector should contact their SACS. If 

an inspection is not conducted, the inspector should document the visit on their 

Weekly Activity Report, but it should not be cited as an Attempted Inspection.

Examples of situations where the inspector may choose not to conduct an 

inspection include, but are not limited to:

• Contagious disease in the animal facility, such as parvovirus (the inspector 

may want to contact the attending veterinarian for more information)

• Illness of the licensee or close family member

• Personal events such as weddings, funerals, doctor/veterinarian 

appointments, or family emergencies

4.3.6.3. Inspections with Facility Representatives

If the licensee or registrant agrees to utilize a facility representative in order to 

conduct an inspection, the inspector must be sensitive to the licensee’s or 

registrant’s wishes and should give them the opportunity to address issues that 

arise during the inspection and/or be involved in the exit briefing. 

In order to accommodate the request, up to two business days can be allowed 

for extra time to answer questions, address concerns identified during the 

inspection, and complete an exit briefing with the licensee or registrant. This 

courtesy will help to alleviate some of the potential hesitation associated with 

utilizing a facility representative. This option should be offered as a potential 

solution to conduct a successful facility inspection.
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The Facility Contact Worksheet

The Facility Contact Worksheet should be updated, as needed, to maintain 

current optimal hours, contact information, and facility representative 

information. 

This worksheet must be uploaded into eFile within five business days. 

Optimal Hours

The inspector should attempt to identify the optimal hours of inspection for all 

licensees and registrants that are not open to the public. Record the optimal 

hours on the Facility Contact Worksheet. Optimal hours are generally four-hour

blocks of time during daylight hours three days per week. This is not, however, a 

requirement. The inspector should use their professional judgment to consider 

two entire days per week, or another set of optimal hours, that will facilitate the 

unannounced inspection. If, after discussion, the suggested optimal hours still 

seem unworkable, the inspector should contact their SACS.

If the licensee/registrant is not at home during the designated hours, cite as an 

Attempted Inspection. If the inspector stops by the facility at other times and 

the licensee/registrant is not home, the inspector should record the visit on their 

Time and Attendance sheet, but the inspector should not cite the inspection as 

an Attempted Inspection.

4.3.8.1. Unsatisfactory Optimal Hours Form Letter

The Unsatisfactory Optimal Hours Response Letter (UOHRL) is an optional form 

that can be used on a case by case basis when the supervisor, inspector, and 

licensee/registrant cannot agree on acceptable optimal hours of inspection. 

Once the supervisor has determined that the OHFL is appropriate, the inspector 

should complete the letter and send it to the licensee/registrant via certified 

mail with return receipt. A copy of the letter should be uploaded into eFile. 

The UOHRL can be sent at any point when unsatisfactory optimal hours have 

been given and the supervisor, along with the inspector, feel the letter would be 

beneficial. This is a separate letter than the “Attempted Inspection Letter” and 

“Benefits of Inspection and Optimal Hours Enclosure”. See Section 4.3.1 

Attempted Inspection General Procedures for more information on the 

“Attempted Inspection Letter”.

Handy Tips

• When attempting to reach a licensee or registrant with limited availability:

o Attempt to call 7 to 8 am, 5 to 7 pm, or over the noon hour if the 

inspector knows the licensee/registrant works during the day

o Try calling at different times during the day

o Always leave a message with a return phone number
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• If traveling near their facility, stop by and leave a “Leave-behind Flyer”. 

Document that a flyer was left at the facility, and the date it was left, in the 

notes section of the “Attempted Inspection Checklist.”

On routine inspections, or other contact with the licensee or registrant, remind 

them to reach out with changes in their schedule, vacations, times when they 

know they will not be home, or optimal hour changes.
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4.4. Auction Market Inspection

The auction market operator and the consigner of the animal, if the consigner is 

licensed or required to be licensed, are responsible for compliance with all 

applicable Regulations and Standards

Criteria

At the time of the Prelicensing Inspection(s) of the auction facility and during 

Routine Inspections, the inspector should ensure that the applicant/auction 

operator understands all the applicable Regulations and Standards emphasizing 

the following:

• All animals must be handled so there is minimal risk of harm to the animals 

and the public. Operators of auctions during public exhibition should use 

sufficient barriers and/or distance so as to ensure the safety of the animals 

and public. A sufficient number of readily identifiable attendants should be 

present at all periods of public contact with the animals [2.131]

• Incompatible animals must not be held in the same enclosure

• Requirements for record keeping, transportation, cleaning, sanitation, and 

general animal health and well-being are monitored and met during the 

auction

• The animal enclosures meet the space requirements:

o Animals are considered to be “in transit” and may remain in the 

enclosures while at the auction as long as all requirements for transport 

enclosures (from the Transportation Standards for the appropriate 

species) are met or exceeded

• The auction operator is responsible for compliance with all Regulations and 

Standards, including applicable Transportation Standards, once the animal is 

accepted by the auction market. The auction’s responsibility does not 

extend to animals kept in transport vehicles in auction parking lots.

At the time of the auction, you (the inspector) should:

1. Contact the licensee or his/her representative at the facility

2. Introduce yourself

3. Show official ID, if requested

4. Ask the licensee or representative if:

o He/she or a designated person should accompany you around the 

auction grounds, or

o If it is permissible for you to inspect the grounds and the sellers/buyers 

on your own

5. Check for regulated animals
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6. If a USDA licensee brings in a regulated animal, conduct an inspection of the 

animal in transit

7. If an unlicensed person brings in a regulated animal:

A. Inform the person of the Animal Welfare Act licensing requirement and 

that regulated activities may not be conducted without a license

B. Explain the Regulations and Standards for his/her animals

C. Give the person an application packet, if appropriate, or contact 

information for the AWO office to obtain an application packet

8. Answer any applicable questions

9. Check the animals for any visible signs of illness or distress (see Animals 

Requiring Veterinary Care).

10. If a licensee purchases and transports a regulated animal, conduct an 

inspection of the animal in transit prior to the licensee leaving the auction 

facility, if possible

Animals Requiring Veterinary Care

The auction operator is responsible for obtaining veterinary care for sick animals 

in his/her custody being sold for regulated purposes.

If a licensee has transported a sick or injured animal, the inspector should ask if 

the attending veterinarian or a veterinarian at the auction has been contacted. 

If not, the licensee should be cited for this noncompliance.

Records

4.4.3.1. Sale Day

Ensure that licensees who have transported dogs, cats, and nonhuman primates 

across a State line have health certificates. The auction operator is not required 

to maintain a copy of these records.

4.4.3.2. After the Sale Day

Conduct an inspection of the records containing all the information for the 

animals consigned to and sold by the auction operator on a different day than 

the sale day.

NOTICE

If a noncompliant item is noted at the time of consignment, inform the 

auction operator or auction representative of this noncompliance.
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4.4.3.3. Acquisition Records Follow-Up

A person consigning a regulated animal to an auction market may or may not

require a USDA dealer’s license.

Consignment of regulated animals to an auction is not sufficient cause alone for 

requiring a license since the consignor may be exempt from licensing under 

Section 2.1(a)(3) of the Regulations or excluded.

The inspector should:

1. Collect the names/addresses of unlicensed persons consigning regulated 

animals to the auction

2. As time permits, conduct a search of any unlicensed person in your area 

selling regulated animals to determine if he/she is conducting any regulated 

activities

3. Send sales information for unlicensed persons not in your area to the 

appropriate SACS or inspector to conduct a search if deemed necessary

NOTICE

The auction catalog is a good source for this information and should be 

obtained, if available.
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4.5. Barrier Facility Inspection

Animals housed in a barrier facility must be maintained in accordance with all 

Animal Welfare Act Regulations and Standards. Barrier facilities can include but 

are not limited to quarantine/isolation areas, areas conducting research with 

infectious agents, areas housing animals that are Specific Pathogen Free (SPF) or 

gnotobiotic.

Criteria

The inspector must be able to inspect all regulated animals and all animalrelated areas at a licensed barrier facility to ensure compliance.

If it is not possible for the inspector to enter the animal rooms in the barrier 

facility due to the possibility of disease exposure and/or contamination of the 

inspector or the animals, the inspection may be conducted by:

• Analyzing environmental records.

• Selecting random animals to be visually inspected

• Video viewing from outside the barrier room

• Visual inspection through an adequate viewing window

The inspector should follow the entry procedures normally used by the facility’s 

personnel.

The facility should:

• Not require more stringent entry Standards for the inspector

• Provide the protective clothing and supplies needed to complete the 

inspection, such as pen, paper, flashlight, etc., if the facility will not allow you 

to take your own supplies into the barrier area

• Provide a means of taking photographs, such as taking the photos for you or 

providing a disposable camera, if the facility will not allow you to take your 

camera into the barrier area or you are conducting the inspection from 

outside the barrier area

The facility may ask the inspector to verify that he/she has not been in contact 

with, or exposed to, certain animals for a specified period of time, generally 72 

hours. This verification is acceptable.

NOTICE

The facility should supply a copy of its barrier entry procedures upon request.

NOTICE

Do not sign any statement which places you responsible for the health of the 

animals in the barrier facility.
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All supplies required to maintain compliance should be available within the 

barrier facility. For example, veterinary equipment required for the procedures 

should be present in a surgery room behind a barrier when surgical activities are 

conducted.

Alternative Methods of Inspection

4.5.2.1. Video Camera Inspection

If a video camera is to be used for inspecting the barrier facility, the facility 

should meet the following minimum guidelines:

• If possible, record the inspection so the inspector and licensee or designated 

person can refer back to the recording to review an area if any questions 

arise after the facility inspection

• Have sufficient or supplemental lighting in the room to allow for good 

visibility

• Have a color monitor so that color differences can be seen. For example: to 

distinguish blood from other fluids, or to see algae/scum growth in water.

• Have a communication system between the person operating the camera 

and the inspector so that the inspector can direct the person to view 

different areas, or zoom in on an area

• A high-resolution video camera should be used so that the inspector can 

clearly see the animals in the enclosures and see subtle differences, such as 

being able to distinguish between bedding and feces in or beneath the 

enclosures

• Use a portable video camera with the ability to video all parts of all the 

rooms that will require inspection, such as the animal rooms, food and 

bedding storage areas, medication storage areas, and enclosure 

washing/sanitizing areas

4.5.2.2. Through a Viewing Window

If the inspection is to be conducted through a viewing window(s), the facility

should meet the following minimum guidelines:

• All parts of all the rooms that will require inspection, such as the animal 

rooms, food and bedding storage areas, medication storage areas, and 

enclosure washing/sanitizing areas, must be visible through the window(s)

• The lighting in the room must be sufficient to allow for good visibility or the 

facility must have supplemental lighting available

• There must be a communication system between the person inside the room 

and the inspector, so that the inspector can direct the person to bring 

enclosures or animals to the window, or to open cabinets or containers
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4.6. Change in Class of License Inspection

A licensee must complete the prelicense process to change his/her class of 

license. Refer to Chapter 4 for information regarding the prelicense process. 

If during an inspection, you determine that the licensee has the wrong class of 

license for the regulated activity that he/she is conducting:

• You may not start the prelicense process to change the license. The licensee 

must follow the procedures for applying for a new license, i.e., submit an 

application, pay the license fee, etc.

A ‘Class A’ licensee is anyone meeting the definition of “dealer” whose business 

consists only of animals acquired for the sole purpose of maintaining or 

enhancing the breeding colony and animals that are bred and raised on the 

premises.

A ‘Class B’ licensee is anyone meeting the definition of “dealer” whose business 

includes the purchase and/or resale of any animal. Class B licensees include 

brokers and operators of auction sales, as such individuals who negotiate or 

arrange for the purchase, sale, or transport of animals in commerce. A Class B 

dealer may also exhibit animals as a minor part of the business.

A ‘Class C’ licensee is anyone meeting the definition of “exhibitor” whose 

business involves showing or displaying animals to the public. A Class C exhibitor 

may buy and sell animals as a minor part of the business to maintain or add to 

the animal collection.

Criteria

To change his/her class of license, a licensee must:

• Complete an Application for License–New License (APHIS Form 7003A–

Application for License)

• Complete an announced Prelicense Inspection with no noncompliant items 

cited

• Send a cancellation form for the old license to the AWO Field Office

If the inspector finds that a licensee has changed or plans to change his/her 

regulated activity, notify the licensee that he/she needs a different class of 

license and:

• Must complete an Application for License–New License (APHIS Form 7003A–

Application for License), complete the TIN form, and pay the license fee

• Must not conduct the unlicensed activity until the new license is issued, but 

may conduct the regulated activities covered under the current license

The licensee should request an application packet from the Ft. Collins Animal 

Welfare Operations Field Office, if necessary.
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Conducting the Inspection

4.6.2.1. Noncompliant Items Identified

If noncompliant items are identified during the inspection:

1. Enter the Inspection Report into eFile under the Prelicense site.

A. Make sure no license number is visible in the certificate box in the eFile

screen for that new site

B. If the licensee does not have a new Prelicense site, contact Program 

Support to add a new site

2. Classify the inspection as “Prelicense #1”

3. Inform the licensee that he/she cannot conduct the new activity if it is not 

allowed under his/her current license. For example, a Class A dealer wants 

to exhibit animals.

4. Add the statement to the report “NO CLASS (enter class of license) 

ACTIVITIES MAY BE CONDUCTED UNTIL A VALID USDA CLASS (enter class of 

license) LICENSE IS OBTAINED.”

5. Schedule another inspection, if possible

4.6.2.2. No Noncompliant Items Identified

If no noncompliant items are identified on the inspection:

1. Enter the Inspection Report into eFile under the new Prelicense site.

A. Make sure no license number is visible in the certificate box in the eFile

screen for that new site

B. If the licensee does not have a new Prelicense site, contact the AWO 

Office to add a new site

2. Classify the inspection as “Prelicense Inspection #1”

3. Follow the procedure for a Prelicense Inspection as detailed in Chapter 4 

4. Add the statement to the report “NO CLASS (enter class of license) 

ACTIVITIES MAY BE CONDUCTED UNTIL A VALID USDA CLASS (enter class of 

license) LICENSE IS OBTAINED.”

5. Have the licensee send the license fee, and the voluntary cancellation form 

for the old license to the AWO Field Office.

NOTICE

If the licensee changes his/her class of license prior to the expiration date of 

the previous license, no refund of the previous license fee is given.
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4.7. Complaint Inspection

A complaint inspection is conducted in response to an animal welfare concern 

received by Animal Care. 

Sources of Information

Sources of information include, but are not limited to:

• General public

• Non-government organization

• Another Federal agency

• City, county, or State agency

• APHIS personnel

• Whistle blower

Methods of obtaining information include, but are not limited to:

• Email

• Fax

• Letter

• Personal contact

• Phone call

Receipt of the Complaint Information

If the inspector receives a complaint directly from the public, State or local 

official, humane society, etc., discuss the issue with the complainant to 

determine if the complaint information applies to the AWA and/or the Animal 

Care Program. 

If the complaint information does not apply to the AWA or Animal Care, explain 

the AWA Regulations and Standards to the complainant and refer the 

complainant to another agency (e.g., U.S. Fish and Wildlife, State wildlife or 

animal welfare agency, local animal control, or humane society) if appropriate.

If the complaint information is a possible noncompliance, instruct the 

complainant how to file an animal welfare complaint, either by contacting the 

AWO Field Office or through the Animal Care Website.

NOTICE

An inspector may never reveal, or confirm, the source of any complaint.

The complainant does NOT have to give his/her name to file a complaint. 

If the complainant does provide his/her name, it may be subject to a Freedom 

of Information Act (FOIA) request.
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If the complainant does not want to file the complaint, collect all the information 

and contact your SACS.

The inspector should receive a notification from the AWO Office when the 

complaint is entered into eFile.

Responding to the Complaint

The usual time frame for responding to a complaint is 30 days if an inspection is 

required. However, the response time may depend on the severity of the 

situation. The response time may be:

• Within 24 hours when:

o The animal’s health and well-being are threatened, e.g., an elephant is 

locked up in a truck on a hot day; or an extremely ill tiger is not being 

cared for properly

o The public’s safety is threatened, e.g., unsafe enclosures for dangerous 

animals, or unsafe handling of non-caged dangerous animals.

• As directed by your SACS or other program official for a situation with high 

public attention or Headquarters /Administration involvement.

Information Follow-Up

After you have followed up on the complaint, you should:

• Complete an Inspection Report, if appropriate

• Complete the Animal Welfare Complaint Sheet in eFile

The SACS should review the completed Complaint Form. 

NOTICE

For elephant complaints, the SACS must discuss the plan to address the 

complaint with the AWO Director before assigning an inspector and/or 

addressing the complaint. 
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4.8. Courtesy Visits

Courtesy Visits are opportunities for Animal Care to provide learning 

opportunities and build relationships with facilities. A Courtesy Call may be 

conducted as opposed to a face-to-face visit as appropriate. 

General Information

Courtesy Visits are appropriate for:

• Facilities that are considering seeking licensure or registration under the 

AWA

• Facilities seeking guidance or suggestions regarding how to ensure that they 

meet compliance Standards 

• Facilities seeking to improve their understanding of the AWA requirements, 

and to verify that improvements they are making meet compliance Standards

Courtesy Visits are scheduled and announced in advance. 

If an inspector goes to a facility for an unannounced inspection:

• An inspection must be conducted

• A Courtesy Visit may be scheduled for another time, but you cannot perform 

a Courtesy Visit in lieu of an inspection

Courtesy Visits should not influence or change the inspection or enforcement 

process at a facility. 

A Courtesy Visit is not a Compliance Visit. Compliance Visits, which are 

conducted by Compliance Specialists (or SACS for research facilities), are visits to 

follow-up with the licensee/registrant on the noncompliant items and provide 

personalized assistance for the compliance challenges. If you think a Compliance 

Visit is more appropriate, you should discuss this with your SACS. 

If you are unsure if it is appropriate to conduct a Courtesy Visit at a facility or if a 

facility requests more than one Courtesy Visit, contact your supervisor for 

guidance. 

If you get a request for a Courtesy Visit but are unable to fit it into your schedule, 

contact your supervisor to see if coverage can be obtained.

Documenting a Courtesy Visit

All Courtesy Visits, whether at regulated or non-regulated facilities, must be 

documented in eFile:

NOTICE

Courtesy Visits are not permitted after the 1st or 2nd prelicense/relicense 

inspections.
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• If two or more employees are involved in the activity, only one employee will 

make the entry into eFile 

• If the visit is not a follow up to a noncompliant item(s), the home or lead 

inspector will make the entry

• If the customer does not have a CID, contact Program Support to have one 

created and then enter the activity

• The specific activity should be entered into eFile. For the Description, enter

the specific corresponding activity type that most appropriately describes the 

visit, using the following definitions:

1. Courtesy visit with applicant: These visits are to ensure an applicant 

understands the Regulations and Standards and is prepared for the first 

Prelicense Inspection. These visits are done prior to the first Prelicense 

Inspection.

2. Courtesy call to applicant: Same as “courtesy visit with applicant,” except 

done via telephone as opposed to face-to-face. In addition to calls made 

before the first Prelicense Inspection, these calls can also be made between 

the first and second, and/or between the second and third Prelicense 

Inspection. This includes emails and texts for the same purpose.

3. Courtesy visit to follow up on compliance concerns: Face-to-face visit with 

the licensee/registrant (L/R) to ensure that the L/R understands how to 

correct a noncompliance of the Regulations or Standards, including teachable 

moments

4. Courtesy call to follow up on compliance concerns: Same as “courtesy visit 

to follow up on compliance concerns,” except done via telephone as opposed 

to face-to-face. This includes emails and texts for the same purpose.

5. Courtesy visit due to change in circumstance (new building, species, etc.): 

Face-to-face visit with a L/R to review a new, or “in-the-works,” project to 

determine if it would be in compliance with the applicable Regulations or 

Standards. Examples include but are not limited to: new construction, new 

research proposal, acquisition of a new species, new site, new handling 

methods, etc. 

6. Courtesy call due to change in circumstance (new building, species, etc.): 

Same as “courtesy visit due to change in circumstance,” except done via 

NOTICE

“Courtesy call to applicant” is not the standard call made to all applicants as 

part of the prelicense process. It is in addition to that call.

Courtesy visits and calls to applicants also include visits and calls to ‘potential’ 

applicants who are seeking guidance about whether their facility would be in 

compliance.
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telephone as opposed to face-to-face. This includes emails and texts for the 

same purpose

7. Courtesy visit with the attending veterinarian (AV): These visits are to 

establish and/or maintain and/or develop a relationship with a facility’s AV. 

Visits with the AV to discuss a potential noncompliant item or a specific 

veterinary care issue identified during an inspection are not considered 

courtesy visits; they are part of the inspection process.

8. Courtesy calls to the attending veterinarian: Same as “courtesy visit with 

the attending veterinarian,” except done via telephone as opposed to faceto-face. This includes emails and texts for the same purpose.

Conducting the Courtesy Visit

UNLICENSED/UNREGISTERED FACILITY

For a facility that is NOT licensed or registered:

• Discuss AWA requirements for the type of facility being visited and ensure 

the representative understands the expectations

• Offer to walk through the facilities and animal areas, and provide feedback 

regarding the facility’s level of compliance

LICENSED/REGISTERED FACILITY

For a current licensee or registrant: 

• Offer to look at areas they are concerned with, and offer suggestions for 

short and long-term compliance and/or where they can obtain helpful 

information

• If a Direct noncompliance is identified during the courtesy visit, the L/R 

should be instructed to address the cause of the noncompliance 

immediately, and promptly notify your supervisor 

NOTICE

If a “Direct” animal welfare problem(s) is identified during a Courtesy Visit at 

a facility that is not licensed or registered, write a memo describing the areas 

of concern and contact your supervisor or the SOTW for guidance.
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Courtesy Visits, when used appropriately, can be a valuable tool to improve 

compliance, and can promote animal welfare at some facilities. 

NOTICE

If a Direct NCI(s) is identified during a Courtesy Visit at a licensed/ registered 

facility, the Courtesy Visit does not become an inspection and an Inspection 

Report is not completed. Instruct the licensee/registrant to correct the 

NCI(s), and promptly notify your supervisor to discuss how to follow up on the 

Direct. For example:

• Return and conduct an unannounced inspection in 1 or 2 days

• Return and conduct an unannounced inspection with a VMO in 1 or 2 

days

• Call the licensee/registrant to determine what action has been taken

• Call and discuss with the Attending Veterinarian
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4.9. Dead Animal/Parts or Serum/Blood Dealer Inspection

A dealer who sells dead animals, unborn animals, organs, limbs, blood, serum, or 

other body parts of regulated animals must meet all applicable Regulations and 

Standards.

Dead Animal/Parts 

4.9.1.1. General Information

4.9.1.1.1 Dogs and Cats

If the animals arrive at the premises dead, specific areas to inspect include, but 

are not limited to:

• Records of acquisition

• Records of disposition

If the dogs/cats arrive at the premises alive and are held prior to euthanasia, the 

facility must meet all the applicable Standards, including official USDA 

identification. A complete inspection should be conducted.

4.9.1.1.2 All Animals Other Than Dogs and Cats

If the licensee does not acquire nor take control of the animals prior to the 

animals’ deaths, no records are required.

If the animals arrive at the premises alive and are euthanized upon arrival, 

specific areas to inspect include, but are not limited to:

• Animal holding/euthanasia area

• Euthanasia procedures

• Acquisition and Disposition Records

If the animals arrive at the premises alive and are held prior to euthanasia, 

conduct a complete inspection.

Blood and Serum Collection

A dealer’s procedure for collection of blood and serum should be evaluated 

carefully to ensure the welfare of the animals. Removal of excessive amounts of 

blood may have negative effects on the animal.

4.9.2.1. General Guidelines

If an animal is held long-term for collection of blood and/or serum, the inspector 

procedure should review:

• Volume per collection

o Normally, the maximum amount of blood that should be withdrawn in 

one bleeding is 15% of the total blood volume (TBV)
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o TBV is usually estimated to be 5 – 10% of total body weight (TBW) for 

most species, with one gram equal to one milliliter

• Frequency of collection

• An animal has to recover from the previous blood draw before another blood 

draw

o Recovery times usually range from 1 – 4 weeks depending on the species 

and volume of blood drawn

• Long-term care

If the inspector has concerns about the amount of blood being drawn or the 

frequency of collection, he/she should discuss with the attending veterinarian 

and/or his/her SACS. 
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4.10. Dogs and Cats in Residence Inspection

Inspecting dogs and/or cats that are being kept and/or bred inside the licensee 

or applicant’s home can be challenging. Many of the Standards used during 

routine kennel/cattery inspections are not applicable. It is important that the 

inspector take the overall conditions into account in making a determination and

always contact a supervisor if there are questions. Please note the following: 

• All regulated dogs and cats must be officially identified and listed on the 

appropriate animal inventory form

• Do not enter or stay in a residence unless you are sure you are safe

• Do not intrude into areas of the home which are not critical to evaluating the 

conditions for the regulated dogs or cats

• Do not open cabinets, refrigerators, drawers, or doors unless you have the 

expressed permission of the owner and the contents are directly related to 

the care of the dogs or cats

• Do not refer to the facility as a “house”, “home”, or “residence” on an 

Inspection Report. Use the term “facility”, or some other mutually agreeable

term such as “small dog area” or “retired breeder housing area.”

• Do not use the impervious surfaces Standards under sections 3.2(d), 3.26(d), 

or 3.51(d), unless there is a designated housing or whelping area inside the 

home. For example, a bathroom used for whelping should have surfaces that 

can be sanitized but that applies to the bathroom area only. A living room 

where dogs hang out and watch television cannot be required to have 

surfaces that are impervious to moisture.

• Focus on the health of the animals and any direct hazards to their health or 

safety, particularly in areas not dedicated to housing animals. For example, 

in the living room, you would be looking at the health of the animals and 

such potential hazards as access to electric wires, bleach, choking or 

ingestion hazards, or significant waste disposal issues.

• Occasionally, a mudroom, laundry room, enclosed porch, or bathroom is 

used as a designated whelping or housing area. When animals are present, 

these areas must provide adequate temperature and ventilation and be 

easily cleaned and sanitized for the health of the animals.

• Wear clean boots or shoe covers to enter the premises. Do not use the same 

boots or shoe covers in which you inspected any other kennel/cattery

buildings.

• When photographs are required, be extremely careful to only photograph 

what is necessary to document the noncompliance. Be sensitive to the fact 

that taking a large number of photographs in someone’s house or

photographing personal belongings may add stress to the inspection process. 

Take the minimum number of photographs needed.

It is important to be sensitive to the fact that this is the licensee’s or applicant’s 
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home and act accordingly. There is no limit under the AWA on the number of 

pets that a person can have in their house. We know from experience that a 

large number of dogs or cats housed in a residence can create unhealthy 

conditions. If you encounter an unusually large number of dogs or cats in a 

residence, or have concerns about general conditions in a residence, postpone 

the completion of the inspection and contact your supervisor.
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4.11. Domestic Hoofstock Inspection

A dealer, exhibitor or research facility using domestic hoofstock who does not 

meet the AWA exclusions or exemptions must meet all applicable Regulations 

and Standards, including the Transportation Standards.

Domestic hoofstock are:

• Alpacas

• Cows

• Goats

• Llamas

• Pigs and mini-pigs

• Sheep

• Hybrid crosses of the above animals

Domestic Hoofstock Housed in an Agricultural Setting

Agricultural settings include, but are not limited to:

• Pastures or ranges

• Outdoor pens with shelters and/or barns

• Production housing 

When inspecting an agricultural setting, the inspector should use Subpart F of 

the AWA Standards. The inspector may also refer to the Guide for the Care and 

Use of Agricultural Animals in Teaching and Research, Third Edition, January 

2010.

Domestic Hoofstock Housed in a Non-Agricultural Setting

Non-agricultural settings include, but are not limited to:

• Zoos

• Indoor displays such as nature centers or sportsman shows 

• Research facilities

When inspecting a non-agricultural setting, the inspector should use Subpart F of 

the AWA Standards.
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4.12. Drive-through Zoo/Park Inspection

A zoo or animal park which allows people to drive through, either in their own 

vehicles or a zoo/park vehicle, must meet all applicable Regulations and 

Standards.

Consider a team inspection for drive-through parks. 

In addition to the regular equipment, inspectors should bring:

• Binoculars for each inspector to facilitate viewing of animals 

• Cameras with adequate zoom to photograph animals at a distance

Conducting the Inspection

4.12.1.1. Driving through the Zoo/Park

Driving through the facility for inspection can be done in a facility–owned vehicle 

or in a GOV:

• Due to restrictions on the use of GOVs, the facility representative cannot 

accompany the inspectors in a government vehicle

• During the inspection, it is acceptable to ride in a vehicle provided and driven 

by the facility representative

Safety while driving through the zoo/park:

• Pay particular attention to safety while moving

• Watch for animals and other vehicles in the roadways

• Driver’s attention should be focused on driving safely

• Passenger should be taking notes, photographs, and observing animals

Regardless of whose vehicle is used, it is important to:

• Drive slowly

• Stop frequently to observe the animals and their behavior

• Stop in locations where you can view animals congregating

• Pay particular attention to animals that may be isolated from the groups

• Observe the other vehicles driving through the zoo/park

• Watch for public interactions with the animals

• If public feeding is allowed, observe how it is accomplished
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Animal Inspection

Inspectors should evaluate the licensee’s methods for providing both routine 

herd-wide preventative health care (as required by the facility’s attending 

veterinarian) as well as care to individual animals that may become sick or 

injured. These methods may include:

• Annual or semi-annual animal ‘round ups’ where preventative care such as 

vaccination and deworming can be administered to all animals

• Moving individual animals into smaller areas to facilitate treatment using 

training or chutes 

• Chemical immobilization administered by a remote delivery system

To help evaluate the handling methods, ask or look at:

• The equipment in use, such as:

o Chutes

o Drugs

o Remote drug delivery systems

• Ensure that the equipment and drugs are appropriate for: 

o The species

o Setting/terrain 

Expansive habitats may necessitate the use of chemical capture and restraint 

drugs. To be considered adequate veterinary care the facility staff must be 

trained in their use and have the appropriate facilities and equipment to respond 

to adverse events if they occur. 

Handling

When inspecting for compliance with the Handling Regulations at a drivethrough zoo/park, some recommended items to evaluate include, but are not 

limited to:

• Compatibility of the animals in an area

• Caution signs, such as:

o Do not get out of car

NOTICE

When inspectors are conducting the inspection from a GOV, the facility 

representative can accompany the inspectors by driving behind the 

inspectors’ vehicle. In this case, cell phones or a radio may be used to point 

out any potential noncompliance or to ask questions that may arise.
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o Do not put fingers in cages

o Feeding only allowed when facility attendants are present

• Posting or distribution of the safety rules

• Monitoring of the zoo/park by employees during their regular duties

• Number of employees/attendants to patrol the zoo/park

• Monitoring of areas not readily visible to attendants

• Procedure in the event of an animal escape or attack

Public Feeding

The public may not bring outside food into the facility for public feeding. Food 

must be provided by the facility [2.131(d)(4)]. Remember to ask questions about 

measures that the facility has in place to prevent this practice and what actions 

are taken if this situation is found by the facility. 

Food offered to the animals must be:

• Wholesome

• Palatable

• Presented in an appropriate manner

There are many methods for public feeding at drive-through zoos/parks which 

may be compliant. For example:

• Facilities use designated areas for feeding so that attendants can be present 

at those areas. Feeding in other areas is not permitted and the facilities have 

methods in place to discourage this practice.

• Facilities only permit feeding from facility operated vehicles that have 

sufficient attendants accompanying the public group

• Regular patrolling by facility staff of the feeding area

• Video surveillance of the feeding area with radio dispatch

• Distribution of written policies on feeding, such as handouts given to the 

public stating feeding rules such as, windows must be closed unless a facility 

attendant is present, and no feeding of animals unless an attendant is 

present

• Posted Caution Signs

When public feeding occurs from facility-owned vehicles, inspectors should 

evaluate how many attendants are present and whether they can intervene in 

the event of a problem. When the vehicle driver is the only attendant it may be 

difficult to ensure both animal and visitor safety. This is particularly true for 

large vehicles, those with driver separation from the public, or horse drawn 

vehicles. 
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Facility Inspection

When inspecting drive-through zoos, remember to evaluate all aspects of the 

facilities. 

Ask about alternate housing. Many drive-through zoos/parks:

• Move a portion of the animals to alternate housing

• Rotate pastures

• May close for a portion of the year and move the animals 

4.12.5.1. Separation of Businesses

Some drive-through zoos/parks also have other animal-related activities that are 

not considered by the park’s owner to be part of the regulated enterprise, such 

as production farms or hunting preserves. It is important to determine what is 

regulated and what is exempt:

• Generally regulated if:

o The animals are all comingled throughout the facility pastures or 

enclosures

o The animals are viewed by the public during their visit to the facility

o The animals from an off-site area are brought to and from the exhibit site

4.12.5.2. Animal Compatibility

Drive-through zoos/parks often have large multi-species enclosures. This can 

lead to compatibility issues if care is not taken in selecting the species and 

individual animals. 

During inspection:

• Pay attention to animal interactions particularly around resources such as 

feeders, water sources, shelter, etc. 

• Assess body condition. This can also be helpful in determining whether 

animals are getting adequate feed or if competition is negatively impacting 

them. 

• Remember, not all compatibility issues are constant. Seasonal hormonal 

fluctuations associated with breeding season/rutting season can impact both 

intra-species and inter-species compatibility, so vary inspections by time of 

year.

• Evaluate animal records closely to help identify injuries or deaths which may 

be due to compatibility issues 

4.12.5.3. Access to Shelter

Adequate shelter is essential for all animals at all facility types. The large 
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enclosures provide opportunity for naturalistic habitat, but also present unique 

challenges.

Natural shelter such as trees may not be sufficient in all circumstances. 

When natural shelter is not adequate to protect animals from discomfort, 

artificial shelter must be available. 

When evaluating artificial shelter, the inspector should ensure that: 

• There is sufficient space for all animals 

• There are enough shelters for all animals to fit into comfortably

• Shelters are strong enough for all species

4.12.5.4. Access to Potable Water

Ponds and/or streams used as the sole water source may be considered 

adequate potable water. However, the following items must be evaluated:

• Natural stream, river, pond, or lake water should appear clear and there 

should be no indication of animal impacts caused by the water

• When covered by algae, water beneath should appear clear. Presence of 

algae does not mean the water is not potable.

• Ponds may freeze during the winter presenting a hazard for animals when 

the only water source

• Ask the facility representatives to point out potable water sources during 

inspection as additional water sources may be concealed to provide a natural 

looking environment.

4.12.5.5. Environmental Hazards

These natural environmental features may be hazards for some species but be 

appropriate habitat for others. You will need to make determinations about 

safety for the animals. Therefore, when inspecting, remember to:

• Evaluate the physical terrain

• Know the natural history of the animals

• Be aware that some of these hazards change seasonally or between 

inspections

• Evaluate the facility’s program for self-identifying/correcting issues before 

adverse animal impacts occur 

NOTICE

Remember to assess the shelter in combination with compatibility as 

dominant animals may prevent submissive animals from using shelters if 

there is insufficient space.
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• Review the facility records for injuries, deaths, and animals provided 

veterinary care to help evaluate the impact of physical hazards

4.12.5.6. Records 

Exhibitors are required to make, keep, and maintain records of: 

• Acquisition (including births)

• Disposition (including deaths and euthanasia) 

• Animals on hand [for animals other than cats and dogs, see Section 2.75(b) 

(1)]. 

Increased mortality or decreased births can be indicators of both animal health 

and/or welfare problems. Therefore, accurate record keeping is essential for:

• Facilitating communication between the licensee and the attending 

veterinarian

• AC Personnel to evaluate compliance with the AWA Regulations and 

Standards.

• Evaluating effects of natural hazards

• Evaluating compatibility issues

When reviewing records of animal deaths/euthanasia, inspectors should 

remember to ask questions. For example, what were the circumstances 

surrounding the death or serious injury and was appropriate veterinary care 

provided?

4.12.5.7. Necropsy Records

In some circumstances, necropsy examinations may be appropriate as part of the 

provision of adequate veterinary care. For example, if there are:

• Abnormally high death losses

• Significant unexplained mortality

• Other conditions indicative of an undiagnosed infectious disease

Inspectors should request to see documentation of necropsy examinations. If 

such records exist, they must be made available for inspection pursuant to 

section 2.125. 

4.12.5.8. Animal Inventory 

In large drive-through zoos/parks, there may be instances where it is not 

possible to ensure accuracy when counting a particular species during the 

inspection. For example: 

• A large group of fallow deer in expansive multi-acre exhibit 

• Pot-bellied pigs allowed to roam the entire facility
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• Small number of shy animals that are easily hidden in the natural 

environment

• Prairie dogs in a confined space that has only overhead viewing

In these cases, the inspector must assess the accuracy of the records. Examples 

of methods that may be used include, but are not limited to:

• Facilities may record births or deaths as they occur and then confirm total 

numbers of animals on hand at annual or semi-annual ‘round-ups’ where 

routine health procedures are also conducted 

• Although individual animal identification is not specifically required by the 

AWA (for animals other than dogs & cats), licensees may ear-tag or 

otherwise identify individual animals as a best practice 

• Some States may require ear-tag or other type of permanent identification 

for cervids 

If the facility’s method for maintaining records of animals on hand appears 

adequate, inspectors may use the facility’s animal count for the purposes of the 

inspection inventory. 

4.12.5.9. Training and Qualifications 

During the evaluation of records is a good time to ask about the qualifications 

and training of the employees. Employees may be involved in activities that 

require specialized training, such as:

• Immobilization of animals

• Movement of large dangerous hoof stock 

• Movement of very flighty hoof stock

• Determining compatibility among varied species

• Distinguishing between normal and abnormal behavior for a variety of 

species

• Observing illness/injury among a variety of species 

It is important to check that employees are adequately trained and supervised 

by someone who has the necessary knowledge to instruct them.
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4.13. Lion and Tiger Enclosure Inspection

This document provides guidance for assessing lion, tiger, and lion-tiger hybrid 

enclosures under commonly found circumstances at stationary facilities for 

purposes of primary containment. 

Enclosures that clearly do not meet performance Standards for containment as 

per 9 CFR section 3.125(a) must be cited. All citations must refer back to the 

language of the Regulations and Standards; there are no engineering Standards. 

Evaluating Enclosures

Factors to consider when evaluating enclosures include:

• Height. Acceptable fencing for lions, tigers, and lion-tiger hybrids is typically 

a minimum of 12 feet in height, plus an additional method of preventing 

escape, such as, but not limited to:

o A kick-in at the top

o Hotwire attached to the fencing around the entire enclosure with 

sufficient joule rating to prevent the big cat from climbing to the top

o A 2.5 - 3-foot-wide section of non-climbable material such as sheet metal 

attached to the fencing below the top of the entire enclosure fence to 

prevent climbing 

o An enclosure with a completely covered top (Note: Enclosures with a 

complete covered top must be high enough to allow for normal and 

typical behaviors and postures.)

• A wet or dry moat can be used to contain lions, tigers, and lion-tiger hybrids. 

Moats are typically 25 feet wide or greater and 16 feet deep or filled with 5 

feet of water. Remember that if the animal enclosure is higher than where 

the public is standing, additional distance is needed as animals can jump 

farther when going from high to low ground.

• Trees and cage furnishings should be far enough away from the enclosure 

fence to prevent the big cats from climbing out

Note that this guidance is for enclosure design for compliance 9 CFR 3.125(a), 

and does not address handling requirements such as public barriers, which may 

need to be assessed as a separate issue.

NOTICE

If the inspector has any concerns about an enclosure’s ability to contain lions, 

tigers and/or lion tiger hybrids, the inspector should contact his/her 

supervisor and Animal Care’s Big Cat Specialist for guidance.
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Compliant big cat fencing

The inspector should consult with the licensee on an appropriate identifier for 

each enclosure. The identifier may be the name of the animal in the enclosure, 

the location of the enclosure on the premises, an enclosure number, or any 

other agreed upon identifier.
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4.14. Marine Mammal Facility Inspections

A licensee who conducts regulated activity with marine mammals must meet all 

applicable Regulations and Standards, including the Transportation Standards.

Conducting the Inspection

Prior to inspecting a marine mammal facility, you should review the Marine 

Mammal Standards, Subpart E, and the facility’s recent inspection history.

When inspecting a facility with marine mammals, some items to evaluate are 

listed below.

Veterinary Care

Marine mammals must be provided adequate veterinary care, including but not 

limited to:

• All marine mammals must be visually examined by the attending veterinarian 

at least semiannually. Also, all cetacean or sirenian must be physically 

examined by the attending veterinarian annually, unless APHIS grants an 

exception based on considerations related to the health and safety of the 

cetacean or sirenian.

• Each marine mammal must have medical records that include physical 

examination information

• Review records for each animal with medical concerns or under treatment 

first. Verify that animals with inappetence over 24 hours are documented 

and the attending veterinarian has been notified.

• Ask about any births or deaths

• Ask how the facility cleans, disinfects, and stores equipment used for 

medical/husbandry behavior training (e.g., gastric tubes, toothbrush, sample 

collection containers)

• Ask if any marine mammals are in quarantine or isolation and why

• Ensure that quarantine or isolation pools/areas for marine mammals held for 

nonmedical purposes meet the minimum space requirements

• Review the medical records and attending veterinarian justification for any 

marine mammals held for medical purposes for more than 2 weeks in 

quarantine or isolation pools/areas that do not meet the minimum space 

requirements

• Evaluate and inspect holding areas (for isolation, separation, and treatment):

o If a marine mammal is kept separated or isolated, there should be 

veterinary justification and provisions for periodic review of the plan by 

the attending veterinarian

• Review necropsy/histopathology reports
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• Review any incident, husbandry, daily feeding and supplement logs and 

training logs

Space

Marine mammal primary enclosures must meet the space requirements in 

section 3.104.

4.14.3.1. Space requirements for marine mammals housed in unusual 

circumstances

Situations that may require further evaluation of space to assess compliance for 

marine mammal pools may include:

• Irregularly shaped pools

• Pools with islands or obstructions within the swimming area of the animals

• Pools with varying depths, where the shallow areas of the pool do not meet 

the minimum depth requirement for the species housed

• Pools with gates or channels that must be included in the minimum 

horizontal dimension (MHD) calculation for the pool to meet the required 

minimum horizontal dimension

Gather clear documentation necessary to submit to your SACS to thoroughly 

assess the situation. This documentation should include photographs and 

measurements.

Photographic documentation should include, but not be limited to:

• Document the pool(s) using photographs taken from at least two different 

angles, with photos taken across the width and length of the pool, or two 

different views of a round or irregular pool

• Include two-view photographs of obstructions, such as islands or pool 

outcroppings that may impede an animal’s ability to swim within the pool

• Include close-up and distance photographs of channels, gates, and/or narrow 

areas that may require animals to adjust their swimming patterns. Include 

photographs taken looking down from the side of the pool, documenting the 

depth of the channel, gate design, or shallow areas.

• Include photographs of channels, outcroppings, or islands taken from 

underwater viewing windows, when possible

• Try to obtain video footage of the animals swimming in the pool, optimally 

when they are passing through gates, narrow channels, or swimming in a 

pattern around an island, to determine the animals’ ability to navigate the 

narrow or irregular areas or to document the animals’ ability to swim 

through shallow sections that do not meet the depth requirement

Measurements should include, but not be limited to:
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• Measurements of the depth, width and length or circumference of shallow 

areas of the pool that are noncompliant and that require further assessment

• For pools with a sloping bottom, determine from either architectural plans, 

or from your own measurements, the approximate point at which the pool is 

a compliant depth for the largest species housed

• Create a map of the pool indicating the areas meeting the minimum depth 

requirements

• Measure the length, width, and depth of all channels that are necessary for 

the animals to use

• Determine from written records, facility personnel or SOP, the amount of 

time gates are left open for the animals to access separate areas of the pool

• Measure the width, length, and depth of irregular areas of the pool if there is 

a question about calculating the MHD of the pool

Feeding

Food for marine mammals must be wholesome, palatable, and free from 

contamination and must be of sufficient quantity and nutritive value to maintain 

marine mammals in good health.

• To minimize nutrient loss and bacterial contamination, frozen or thawed 

food must be stored, thawed, and prepared properly. At a minimum, you 

should:

• Inquire about the source(s) of the food

• Inquire about types of food being fed and their nutrient analysis. Diets must 

be prepared with consideration for factors such as age, species, condition, 

and size of the marine mammal being fed

• Be aware that fatty fish, such as mackerel and tuna, have a shorter shelf life 

(4-6 months)

• Check freezers and refrigerators to verify proper temperatures. 

Freezers/cold storage must be maintained at a maximum temperature of 0 

degrees F

• Examine the stored food and ask how food is stored and rotated to ensure 

that it maintains optimal nutritive value by minimizing freezer storage time 

and does not become freezer burned

• Check the catch date on boxes - old food loses nutritive value over time

• Verify frozen food has not thawed and refrozen or boxes damaged indicating 

possible contamination:

o Check for water, blood, or ice pooling beneath or frozen to boxes, and

o Check for freezer burn which could affect palatability and moisture 

content of the food. Signs of freezer burn include white or desiccated 
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flesh.

• Ask how food is thawed. Thawing must be conducted in a manner that 

minimizes contamination and will assure that the food retains nutritive value 

and wholesome quality until the time of feeding. When food is thawed in 

standing or running water, cold water must be used.

• Ask to see and examine a representative sample of thawed food to verify 

wholesomeness. Attention should be given to skin appearance, gill color, eye 

clarity, elasticity of the flesh, odor, and condition of viscera.

• Review the diet and amounts fed for each animal and ask how it is 

determined

• Review how calories/needs are calculated

• Review the feeding schedule/frequency

• Ask about supplementation and how it was determined. For example, 

cetaceans should have a multi-vitamin with B1 (Thiamine) at a minimum.

• Review daily food consumption records for each marine mammal

• All food must be fed to marine mammals within 24 hours once removed 

from freezers for thawing

Water Quality

The water in the primary enclosures must not be detrimental to the health of the 

marine mammals. When inspecting pools, at a minimum, you should:

• Ensure that each pool is being monitored and tested

• Look at SOPs for water testing

• Ask about frequency of testing

• Who does testing/where performed? Is it in-house or sent out to the lab?

• Review water quality data for preceding year for ALL pools

• Keep in mind that pools that are rectangular in shape or have a narrow 

passage into another pool should be monitored carefully because dead 

spaces may affect water quality

• If water is tested at an intake valve, the facility may also consider testing 

water taken from another area of the pool

• Daily testing:

o pH must be tested daily:

- A pH between 7.6 and 8.0 is ideal for marine mammal life support 

systems

- Facilities with natural saltwater do not have to test for pH

o Water samples shall be taken and tested at least daily for chemical 
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additives (e.g., chlorine and copper) added to the water to maintain 

water quality standards

• Weekly testing:

o Coliforms must be tested at least weekly

o Coliforms with a consistent value of zero each week may be of concern

o if coliforms exceed 1000MPN/100 ml, action must be taken:

- Two subsequent samples may be taken within 48 hours intervals and 

averaged with the first sample to obtain new count

- If number still exceeds 1000MPN/100 ml, then water is unacceptable

and must be immediately corrected

- Many facilities will do a partial to full water change to correct the 

problem

Check Salinity levels:

o Salinity should range from 15 - 36 PPT (parts per thousand):

- Natural seawater salinity is 32 – 35 PPT

- Salinity less than 20 PPT is likely to cause skin and eye pathology in 

cetaceans

- Eye problems may be observed in pinnipeds housed in fresh or 

brackish water

Shelter and Shade

All marine mammals kept outside must be provided with shelter to afford them 

protection from the weather and direct sunlight.

When inspecting the shelter provided, at a minimum, you should:

• Look carefully at each animal for eye damage which can be caused by 

inadequate shelter from direct sunlight and is a serious, painful health 

concern for both pinnipeds and cetaceans

• Look at supplements being given (Eye-Sea is a common supplement given to 

marine mammals with eye damage and/or to prevent damage)

• Check if any animals have zinc oxide on heads or back. If yes, they may be ill 

and may need additional shelter.

• Observe a training session. Ensure animals are not being asked to look into 

sun during feeding.

• If public feeding is allowed, then observe the activity to ensure that the 

animals are not forced to look directly into the sun while getting their food 

reward

• Shelters can be natural or artificial so long as they are appropriate for the

species concerned when local climatic conditions are taken into 
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consideration. For example, facilities may use moveable umbrellas to 

protect animals’ eyes during training.

Polar bears: The dry resting and social activity area for polar bears must be 

provided with enough shade to accommodate all polar bears housed in the 

primary enclosure at the same time.

Public Barriers

The requirements for public barriers are contained within section 3.101 (a)(2) 

under General Facilities and section 2.131(c)(1) under Handling:

• All marine mammals must be provided with protection from abuse and 

harassment by the viewing public by:

o The use of a sufficient number of readily identifiable employees or 

attendants to supervise the viewing public, or

o The use of physical barriers, or

o A combination of these [3.101(a)(2)]

• During public exhibition, any animal must be handled so there is minimal risk 

of harm to the animal and to the public, with sufficient distance and/or 

barriers between the animals and the general viewing public so as to assure 

the safety of the animals and public [2.131 (c)(1)]

You should routinely observe public viewing areas to verify:

• If employees or attendants are used to protect marine mammals from abuse 

or harassment, then:

o There are a sufficient number of uniformed or readily identifiable 

employees or attendants to supervise the viewing public, and

o The attendants are adequately trained and attentive to the actions of the 

public

• The attendants are able to quickly respond to situations where the public 

potentially could have unsupervised contact with the animals:

o Ask how the attendants would respond to any unsafe behaviors by the 

public. A common problem seen at marine mammal facilities involves 

the accidental or deliberate dropping of inedible items in the pool which 

can pose a serious health hazard if ingested.

• If physical barriers such as fences, walls, or glass partitions, are used, then 

they must be sufficient to protect the marine mammals from abuse and 

harassment by the viewing public and to assure the safety of the animals and 

the public

• If a combination of attendants and physical barriers are used, then they must 

effectively provide protection from abuse and harassment and assure the 

safety of both the marine mammals and the public
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Separation

Marine mammals known to be social in the wild must be housed with at least 

one compatible animal of same or biologically related species, except when the 

attending veterinarian, in consultation with the husbandry/training staff, 

determines that such housing is not in the best interest of the marine mammal’s 

health or well-being.

When inspecting, at a minimum, you should:

• Check that social needs of the marine mammals are being addressed. If 

unsure, contact your SACS for guidance.

• Marine mammals housed together must be compatible and other animals 

housed near the marine mammals must not cause them unreasonable stress 

or discomfort or interfere with their good health

• For marine mammals housed separately, check for a written plan approved 

by attending veterinarian, and developed in consultation with husbandry/ 

training staff, justifying the length of time of the separation and outlining the 

type and frequency of enrichment and interaction to be provided to the 

marine mammal

Employees

A facility must have a sufficient number of adequately trained employees or 

attendants working in concert with the attending veterinarian to maintain the 

husbandry practices as required in the AWA Standards. Such practices must be 

under the supervision of a marine mammal caretaker with demonstrable 

experience in marine mammal husbandry and care.

When inspecting, at a minimum, you should:

• Review written documentation that the employees/attendants have 

successfully completed a facility training course which includes, but is not 

limited to:

o Species appropriate husbandry techniques

o Animal handling techniques

o Proper reporting protocols on recordkeeping

o Notifying veterinary staff of medical concerns

• Check that any training of marine mammals is being done by or under the 

direct supervision of experienced trainers

• Ensure that trainers or handlers meet professionally recognized standards for 

experience and training. If you are unsure, contact your SACS.

• Ask if they have an ongoing or periodic training program which incorporates 

industry standards and best practices
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Recordkeeping

Marine mammal facilities must maintain all records required under Subpart GRecords and any specific records required for marine mammals, such as:

• Medical records for individual animals

• Necropsy records

• Feeding records

• Water quality records

When inspecting records, at a minimum, you should:

• Review all of the required records and ensure they are being kept for 1 year 

(or 3 years for necropsy records)

• Contact National Policy Staff (NPS) if you need to obtain National Oceanic 

and Atmospheric Administration (NOAA) inventory data

• Verify the facility’s inventory and cross reference with NOAA inventory

Swim-with-the-dolphin (SWTD)/Interactive Programs

Section 3.111 Standards have been suspended.
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4.15. New Site Approval Inspection

New site approvals are only required for licensees. Registrants are not required 

to have a new site approved prior to use. 

Animal Care designates housing areas that are roughly 35 miles or further from 

the main address of the licensed or registered facility as separate sites. Site 

designations are used for tracking and inspection management purposes.

If the use of a single site designation causes a major problem at a facility, discuss 

the situation with your SACS.

The amount of time necessary to inspect all housing/exhibition facilities at a site 

is not a rationale for designating a separate site.

The licensee must list all sites and their addresses on the Application for License 

(APHIS Form 7003-A).

New buildings or enclosures at an existing or nearby site do not require preapproval. It is often helpful to perform a courtesy visit of new or proposed 

construction at currently licensed or registered sites, but it is not a requirement. 

All buildings and enclosures in use should be inspected during the routine 

unannounced inspection of the existing site. 

Addition of a Site

A site may be added to an existing license as follows:

• Licensee must notify, preferably by certified mail, the Ft. Collins AWO Field 

Office of the address of the new site

• AWO Field Office will inform the field inspector

• Inspector should schedule an inspection with the licensee as soon as possible 

No additional license fee is required to be paid for the addition of a new site.

No regulated activities may take place at the new site until it has passed 

inspection.

Site Inspection

When conducting a Site Approval inspection, the following guidelines should be 

followed:

• Conduct a complete inspection of the new site

• Inspection type is New Site

• No Teachable Moments may be given; the site must be in full compliance

• No correction date is given if an NCI is identified except for Directs as noted 

below

• If a Direct NCI is identified:
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o Designate the NCI as a “Direct” and assign an appropriate correction 

date, and

o Inform the licensee that an “unannounced” inspection will be conducted 

on or after the correction date to see if the Direct NCI was corrected

o If the licensee contacts the inspector for another Site Approval inspection 

prior to the Direct NCI correction date, document that the Direct NCI is 

corrected on the Inspection Report for that inspection

• No NCI should be designated as a Repeat

4.15.2.1. Completion of the Inspection Report

No NCIs Identified – Site Passes

• Complete an Inspection Report which must include the following 

statements:

o “No noncompliant items identified during this inspection. This inspection 

and exit briefing were conducted with ___ .”

o “This inspection was a site approval inspection.” 

o “This site is now approved for regulated activity.”

NCIs Identified – Site does NOT Pass

• Complete an Inspection Report which must include the following 

statements:

o “This inspection was a site approval inspection.”

o “This site is not ready for approval to conduct activity covered under your 

current Animal Welfare Act License.”

o “Conducting regulated activities at a non-approved site is a violation of 

the Animal Welfare Act.”

o “Please contact your inspector to schedule your next new site approval 

inspection. This inspection and exit briefing were conducted with ___ . “
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4.16. Pet Store Inspection

A pet store licensed as a dealer or exhibitor must meet all applicable Regulations 

and Standards for all the regulated animals in the store except for the exceptions 

detailed below.

Criteria

If a pet store is licensed, all regulated animals in the pet store or under the 

control of the licensee must be inspected and included in the inventory.

Regulated animals commonly encountered in a pet store include, but are not 

limited to:

• Traditional pet types, such as:

o Cat

o Chinchilla

o Dog

o Ferret

o Gerbil

o Guinea pig

o Hamster

o Rabbit

• Wild/exotic animals or pocket pets, such as:

o Chipmunk

o Degu

o Duprasi

o Flying squirrel

o Hedgehog

o Jerboa

o Naked mole rat

o Nonhuman Primate (usually for exhibit)

o Opossum

o Skunk

o Spiny mice

o Sugar glider
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Record Requirements

A pet store must have all the records required of a B-Dealer, such as:

• Program of Veterinary Care

• Acquisition Records except as outlined below

• Disposition Records except as outlined below

• Environmental Enhancement Plan for NHPs if applicable

• Health Certificates if applicable

4.16.2.1. Acquisition Records

A “Record of Acquisition” is required for all regulated animals acquired by the 

pet store.

• Information in 2.75(a) is required, but use of APHIS Form 7005–Record of 

Acquisition of Dogs and Cats on Hand is optional

• Information in 2.75(b) is required, but use of APHIS Form 7020–Record of 

Acquisition, Disposition or Transport of Animals (Other Than Dogs and Cats)

or APHIS Form 7020A-Continuation Sheet for Record of Acquisition, 

Disposition, or Transport of Animals (Other than Dogs and Cats) is optional

4.16.2.2. Disposition Records

A “Record of Disposition” is required only for the animals that were the basis for 

licensing, such as wild/exotic pocket pets, raccoons, primates, etc.

• Use of APHIS Form 7020–Record of Acquisition, Disposition or Transport of 

Animals (Other Than Dogs and Cats) or APHIS Form 7020A-Continuation 

Sheet for Record of Acquisition, Disposition, or Transport of Animals (Other 

than Dogs and Cats) is optional

Identification

Cage cards are an acceptable form of identification for dogs and cats at pet 

stores.
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4.17. Petting Zoo Inspection

Inspection Procedures

4.17.1.1. Handling

Closely observe the handling of the animals when inspecting a petting zoo.

Proper handling of the animals includes, but is not limited to:

• Animals are exhibited only for a period of time and under conditions

consistent with their good health and well-being

• During periods of public contact, an adequate number of employees or

attendants are present at all times. These employees/attendants must be:

o Knowledgeable

o Readily identifiable

o Responsible

o Able to monitor all public interaction with the animals

• If public feeding is allowed, food must be:

o Appropriate for the animal’s nutritional needs and diet

o Appropriate to the type of animal

o Provided by the animal facility

o Properly stored to minimize contamination or loss of nutritional value

• There are adequate public barriers, when appropriate

• There is minimal risk of harm to the animals and the public

• Dangerous animals, such as, but not limited to, lions, tigers, or bears (See

Appendix B must be:

o Separated from the public by a barrier, and/or

o Under the direct control and supervision of a knowledgeable and

experienced handler

4.17.1.2. Public Contact

If young or immature animals are being exhibited, they may not be:

NOTICE

Nondomestic cats 4 weeks (28 days) of age or younger may not be handled by

the public or transported (except for acquiring veterinary care). Public 

handling and/or transportation of these cubs should be cited and designated 

as a Direct or Critical. 
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• Exhibited for periods of time that would be detrimental to their health and 

well-being

• Exposed to rough or excessive public handling

Drugs may not be used to facilitate, allow, or provide for public handling of the 

animals.

4.17.1.3. Miscellaneous

Other items to evaluate include, but are not limited to:

• Animal areas where the public is not allowed

• Cleanliness and sanitation of the enclosures

• Compatibility of the animals in an enclosure

• Condition of the animals

• Enclosure fencing to protect the animals

• Method(s) for allowing animals time away from public contact, such as:

o Large enclosures

o Solid walls on the outside of enclosures

o Limited or controlled access to the animals

• Method(s) for allowing animals time away from view of the public, such as:

o Barns

o Burrows or dens

o Curtained off areas

• Inspect public feed dispensers for:

o Appropriateness of food items for the species

o Cleanliness

NOTICE

At approximately 12 – 16 weeks of age dangerous animals, such as, tigers, 

lions, bears, and wolves (See Appendix B - Dangerous, Potentially Dangerous, 

and Special License Animals) become too big, too fast and too strong to be 

used for public contact. If you encounter a licensee allowing public contact 

with a dangerous animal over 12 weeks of age, contact your SACS. 

NOTICE

You should recommend that the licensee follow the CDC Guidelines for 

protecting the public against enteric pathogens if he/she is not already doing 

so.
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o Accumulation of old food or feed debris, especially at the bottom of the 

dispenser

• Security measures if animals left overnight

• Shelter, shade, cooling and heating appropriate for the environmental 

conditions the animals may experience

• Vehicles used to transport the animals

• Water availability for the environmental conditions

Remember the following housing restrictions:

• Guinea pigs may not be housed in outdoor facilities, unless located in the 

appropriate climate and with prior approval from the AWO Field Office

• Hamsters may not be housed in outdoor facilities

• Rabbits, guinea pigs, and hamsters may not be housed in the same primary 

enclosure with any other species 

Traveling Petting Zoo Itinerary

No fewer than 2 days prior to overnight travel, AWO Field Office must receive a 

document identifying the information required below. This means, that if USPS 

is used, the document must be mailed sufficiently far in advance to arrive at the 

AWO Field Office by the deadline. 

Itinerary information is required for all regulated animals that are away from the 

home site at least overnight for the purpose of exhibition. This does not include 

animals:

• Transported to a veterinary facility for treatment or evaluation

• Relocated for breeding loan

• Relocated during renovations

• Taken home overnight for extensive husbandry care (such as attendants 

taking very young animals home for overnight feedings and monitoring)

The following information must be included in the itinerary document submitted 

to the AWO Field Office:

Exhibitor Information

1. Name of licensee (person exhibiting and transporting the animals)

A. Business name of licensee, if applicable

B. USDA AWA license/registration number

2. Name of owner of animal (for leased, borrowed, loaned, etc. animal)

Animal Information

1. Name of animal
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2. Identification number of animal or identifying characteristics

3. Species of animal (scientific name or common name)

4. Sex and age of animal

Exhibition and Transport Information:

1. Name of exhibition location

2. Address of the exhibition location

3. Dates at the exhibition location

4. Name, date, location (address, directions, GPS location, etc.) of all stops and 

layovers where animals are removed from transport enclosures

If the exhibitor’s travel plans change:

• He/she should contact the AWO Field Office to amend the itinerary

• If the change in itinerary is reported verbally (by telephone for example) and 

not in writing, such as by email or fax, the change in plans must be followed 

by written notification as soon as possible

• If there is an emergency change after USDA business hours (weekdays, 

8:00am to 5:00pm Central Time), the exhibitor must notify the AWO Field 

Office by the next business day

4.17.2.1. No Itinerary Submitted

If you encounter a traveling petting zoo exhibitor:

1. Check eFile for a current itinerary

2. If there is not a current itinerary in eFile, check with Program Support at the 

Ft. Collins AWO Field Office to determine if there is a current itinerary that 

has not yet been entered into eFile

3. If the AWO Field Office confirms that a current itinerary has not been 

submitted, cite the exhibitor under 2.126(c)
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4.18. Photo Shoot Inspection

Anyone providing or using regulated animals for photo shoots may need to be 

licensed and meet all the applicable Regulations and Standards.

Types of Photo Shoots

4.18.1.1. Regulated Photo Shoots

The following types of animal photo shoots require a license, except as 

exempted under the DeMinimus rule, including, but not limited to:

• Photos of people petting or sitting with wild/exotic animals such as:

o Tiger, lion or bear cub, and other baby animals

o Marine mammals

o Nonhuman primates

o Camels or reindeer in nonagricultural or nontraditional settings

• Animal actors/movie animals

• Animals released into a natural setting for the photo

• Photos for advertising or calendars and magazines

4.18.1.2. Exempt Photo Shoots

The following types of photo shoots do not require a license:

• Photos of free-living wild animals

• Pictures of people with their pets 

• Photo shoots with only domesticated farm animals

• Photos shoots at exhibits of traditional farming and agricultural practices 

(such as displays of working animals, such as reindeer pulling a sled or 

working on a farm)

• Photo shoots at exhibits of art portraying traditional farming and agricultural 

settings (such as nativity scenes with a camel or domesticated farm-type 

animal displayed in a barn or other traditional farm-type setting)

• Photo shoots at exhibits with eight or fewer of any combination of the 

NOTICE

Nondomestic cats 4 weeks (28 days) of age or younger may not be 

transported or handled by the public. At approximately 12 - 16 weeks of age 

dangerous animals, such as, tigers, lions, bears, and wolves, become too big, 

too fast and too strong to be used for public contact. If you encounter either 

of these situations, contact your SACS. 
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following types of animals:

o Pet animals

o Small exotic or wild mammals

o Domesticated farm type animals

Conducting the Inspection

When inspecting a photo shoot, you should observe the photo shoot before 

introducing yourself. In addition, time how long the animal is displayed with 

people before being given a rest break. 

Recommended items to observe or evaluate include, but are not limited to:

• Observe the animal(s) for behavioral stress, such as:

o Struggling

o Vocalization

o Pulling at leash or straining

o Panting/increased respiration

o Sleeping

o Limpness

• Age of dangerous animals being used for public contact photos

o Minimum age – 4 weeks; maximum age depends on the animal but for 

dangerous animals generally 12 weeks (See guidance in Chapter 3 

Conducting the Inspection) 

• Availability of potable water

• Observe food and food storage and check feeding schedule

• Availability of veterinary care, if needed

• Housing of the animal(s) when not being used for the photo shoot including, 

but not limited to the ability of the animal to exhibit species typical behaviors

• Measures to protect the safety of the public and the animal(s) such as:

o Adequate attendants

o Plexiglas

o Tethering of animals to secure structures

o Leashing of animals

o Handler(s) located between the dangerous animal and public at all times

• Number of employees available to control the animal(s)

• Off-exhibit area if any

• Procedure in the event of an animal escape or attack
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• Public barriers, especially for animals not currently being used for photos

• Rest periods for the animals. Observe and time how long rest periods are in 

addition to asking how much rest is provided

• Restraint methods for the age and size of the animal(s)

• Safety measures for the movement of the animal from the enclosure to the 

photo shoot and back

• Safety measures if no perimeter fence

• Training and handling experience of the employees

• Transport of the animal to and from the photo shoot. Inspect:

o trailer or vehicle used for transport

o primary container used to house the animal during transport

• Review paperwork such as Program of Veterinary Care, health certificate if 

required, and acquisition records

NOTICE

Drugs and alcohol may not be used to control the animals.
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4.19. Prelicense Inspection Process

All Prelicense (PL) Inspections should be conducted using the Enhanced 

Prelicense Process (EPLP) based on the guidance provided to all inspectors and 

the guidelines in this section. 

Do not conduct a Prelicense Inspection until all the applicant’s/licensee’s 

paperwork has been processed by the Program Section and the inspector has 

been informed that the applicant may be inspected.

There must be regulated animals at the facility at the time of the inspection. If 

this a problem due to State laws/regulations or local ordinances, contact your 

SACS. 

Prelicense Inspections are the best time to help the applicant learn more about 

the AWA Regulations and Standards using the enhanced prelicense process. 

Required written records (e.g., a program of veterinary care and a plan for 

environmental enhancement for nonhuman primates) must be completed by the 

applicant and reviewed by the inspector during a Prelicense Inspection to 

consider the facility in compliance. There must be a written record of animals on 

hand with as much of the required information completed as possible.

All Prelicense Inspection Reports must be hand delivered. If hand delivery is not 

possible, discuss extenuating circumstances with your SACS

For facilities that are relicensing, the process has some differences. See Section 

4.19.7. 

Initial Contact with the Applicant

Prior to conducting the first Prelicense Inspection:

• Contact the applicant within ten days of receiving the notification letter from 

the AWO Field Office

• Schedule and conduct a Prelicense phone discussion

o The discussion can be done in person but not at the same time as the 

Prelicense inspection

o The discussion should be scheduled since it can take 45-90 minutes, and

o The applicant will need time to gather paperwork and prepare questions 

for the discussion

o For this call to be effective, the applicant and the inspector must be 

focused and prepared for the discussion

NOTICE

Courtesy Visits are not permitted after the 1st or 2nd prelicense/relicense 

inspections.
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• Have a phone discussion with the applicant to determine if the facility is 

ready for the First Prelicense Inspection

• Schedule the First Prelicense Inspection

o Let the applicant know this could take 4-6 hours and will involve 

discussion and review of the AWA requirements and an inspection

o Contact your SACS to request second inspector or Compliance Specialist

to accompany you if you feel that you may need assistance

First Prelicense Inspection

4.19.2.1. Conducting the Inspection

Prior to starting the physical inspection: 

• Go through informational materials with the applicant

• Focus on using informational materials that are applicable to all facilities for 

a new applicant

• Remind the applicant that they are legally responsible for being familiar with 

and compliant with the AWA (9 CFR)

• Remind the applicant that interference during the inspection and/or refusal 

to allow an inspection are serious issues

During the inspection of animals and the facility:

• Be sure to inspect all animals used for regulated purposes 

• For dealers with dogs, you must:

o Have the applicant pull all dogs showing signs of medical issues so that 

you can evaluate whether veterinary attention is needed and/or is 

already being provided, and

o Also select ten percent of the remaining dogs for the applicant to pull so 

that you can look for medical issues associated with their mouths, teeth, 

ears, eyes, skin, general condition, etc. Do not just focus on one area; 

take the opportunity to look at the entire dog for medical issues. 

Remember, wear a new pair of gloves after touching each dog or after 

each enclosure.

• If you identify a veterinary care issue that would normally be cited during a 

Routine Inspection, it must be cited on the Inspection Report for the 

Prelicense Inspection

• Inspect the entire facility thoroughly:

o This includes equipment and vehicles intended for use with animals

o Be certain to verify the locations of all animals on site and off site that are 

used or intended for regulated use

• Inspect all housing areas thoroughly:
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o This includes all housing for all regulated animals – even if the applicant 

states it is temporary housing

o If you have a concern about the primary enclosure, especially for large 

carnivores, elephants, great apes, and/or marine mammals, you should 

contact your SACS to discuss

• Inspect all storage areas thoroughly:

o Including vaccine and medication storage

o All food and bedding storage

• NOTE: If the applicant was previously licensed, he/she must re-apply for any 

variance (e.g., perimeter fence, records) granted under the cancelled license. 

For a relicensing inspection, the variance continues to apply as long as the 

circumstances under which the variance was issued have not changed.

4.19.2.2. Handling and Qualifications

For an applicant with large carnivores, elephants, great apes, and/or marine 

mammals, the applicant’s (and employee’s, if applicable) knowledge and 

qualifications and handling practices should be evaluated carefully. If the 

inspector cannot determine if the applicant has adequate experience and 

knowledge of the species being handled, contact the appropriate AC personnel, 

i.e., SACS or species specialist. 

If the experience and qualifications cannot be determined at the First Prelicense 

Inspection, an appropriate statement similar to the following statement should 

be included on the Inspection Report:

“The handling practices, and/or applicant/employee qualifications are under 

review.”

If the handling practices or qualifications require further review, it is the 

responsibility of the inspector to contact his/her SACS to determine how to 

proceed. 

4.19.2.3. Records

During the inspection of records:

• Discuss the required documents for a compliant Prelicense Inspection:

o Record of Acquisition of Dogs and Cats on Hand (APHIS Form 7005) or 

Record of Animals on Hand (APHIS Form 7019 or equivalent):

- For a new applicant, there should be as much detail as possible, such 

as name and address, phone number, directions to seller’s facility, 

some way to contact seller 

o Exercise Plan for Dogs:

- Must be in writing and accurately reflect the conditions at the facility
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- Must be approved by the attending veterinarian

o Plan for Environmental Enhancement (for nonhuman primates)

- Must be in writing and accurately reflect the conditions at the facility

(Optional APHIS Form 7050 may be used.)

- Must be approved by the attending veterinarian

o Written Program of Veterinary Care for Dogs, (required for all facilities 

with dogs)

- The APHIS Form 7002 is not a required form—other methods/forms 

may be used to document the PVC

o Written Program of Veterinary Care for animals other than dogs, if a parttime attending veterinarian is used

- The APHIS Form 7002 is not a required form—other methods/forms 

may be used to document the PVC

4.19.2.4. Post Inspection Procedure

After the physical inspection:

• Discuss all NCIs identified with the applicant

• If there are any NCIs – leave the facility and write the Inspection Report

o This allows you time to write a detailed and thorough report

o For new applicants - This is the first Inspection Report they have ever 

received, and it must help them understand what is expected of them

• Hand deliver the Inspection Report and conduct a thorough exit briefing

• Do not send the Inspection Report by email or certified mail. If you cannot 

hand deliver the Inspection Report, contact your SACS

• Review with the applicant again any areas you believe necessary

o Use PowerPoint files that apply to the situations seen at the Prelicense 

Inspection

o Provide ONLY agency-approved educational materials, such as:

- Dog Breeder Resource Guide

- Copies of the PowerPoints

- Animal Care Aids

- Tech notes

Second Prelicense Inspection

The 2nd Prelicense Inspection, if required, may be scheduled at the time of the 

1st Prelicense Inspection, or you should instruct the applicant to contact you 

when he/she is ready (but within 60 days following the 1st PL inspection).
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During the 2nd PL Inspection:

• Refer to the 1st Prelicense Inspection criteria for guidance

• Conduct a full and complete inspection. Inspect all records, animals, 

facilities, and storage. There are no focused Prelicense Inspections.

• Review additional presentations on Husbandry, Housing, and Transport as 

applicable

Third Prelicense Inspection

If a 3rd PL Inspection is needed:

• There must be at least 2 AC personnel on the inspection. This could be the 

home inspector and another ACI/VMO, a Compliance Specialist, or a 

Supervisor. 

• Work with the applicant to prepare for the inspection and achieve full 

compliance

• Be sure the applicant understands this is the last inspection available for 

compliance and if the applicant does not pass this inspection, he/she must 

wait 6 months to re-apply for a license

During the 3rd PL Inspection:

• Refer to the 1st PL Inspection criteria for guidance

• Conduct a full and complete inspection. Inspect all records, animals, 

facilities, and storage. There are no focused PL Inspections.

• Review with the applicant additional presentations on Husbandry, Housing, 

and Transport as applicable

Completing the Inspection Report

4.19.5.1. No NCIs – Applicant Passes PL Process

If the applicant has a no NCI Inspection Report, he/she passes the PL process.

You should:

• Complete an Inspection Report which must include the following statements:

o “No noncompliant items were identified during this prelicense 

inspection.”

o “This is a (1st/2nd/3rd) Prelicense Inspection for a Class (“A” / “B” / “C”) 

license. The inspection and exit briefing were conducted with the 

Applicant. The Applicant is ready to be licensed under the AWA”

o “A copy of your license will be sent to you without any additional action 

on your part. If you have not received your license within 30 days, please 

contact the USDA at 970-494-7478.”
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• Hand deliver the Inspection Report (required)

• Verify accuracy of application with applicant

• Stress the importance of continued compliance and discuss “Repeat”, 

“Direct” and “Critical” noncompliances with applicants

• Finish with the following CAW Commercial Breeder PowerPoint files, if 

appropriate:

o Identifying Animals and Keeping Records

o Maintaining Your License

• Discuss optimal hours with the applicant and record the days/times in eFile

4.19.5.2. NCIs Identified – Applicant Does NOT Pass PL Process

If the facility is not in full compliance, cite all noncompliant items using the first 

three components of the four-part citation description found in New NCIs Cited

but do not give correction dates.

If the applicant does not pass on the 1st or 2nd Prelicense Inspection:

• Make sure that the applicant is aware of the 60-day time limit from the first 

prelicense inspection and plans accordingly

• Complete an Inspection Report which must include the following statements:

o “This is a (1st/2nd) Prelicense Inspection for a Class (“A” / “B” / “C”) 

license. The inspection and exit briefing were conducted with the 

Applicant.”

o “All items must be in compliance within (2 /1) more inspection(s) or by 

(enter date - 60 days counted from 1st PL Inspection) or the Applicant will 

forfeit the license fee and must wait 6 months to reapply. Please contact 

your inspector to schedule your next Prelicense Inspection.”

o “Conducting regulated activities without a valid USDA license is a 

violation of the Animal Welfare Act.”

• Hand deliver the Inspection Report (required)

• Remind applicant that it is his/her responsibility to contact the inspector 

when ready for the next Prelicense Inspection

• Remind applicant of the actual date (60 days from 1st PL) by which the PL 

process must be completed

If the applicant does not pass on the 3rd Prelicense Inspection:

• Complete the Inspection Report citing all NCIs and cite 2.3(b) to indicate 

NOTICE

Do not designate any noncompliance as a Direct, Critical, or Repeat. 
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failure to come into compliance on the 3rd PL Inspection

• Include the following statements on the Inspection Report:

o Exit briefing statement

o “This was a 3rd Prelicense Inspection for a Class (“A” / “B” / “C”) license. 

The inspection and exit briefing were conducted with the Applicant.”

o “The Applicant has not demonstrated compliance with the Animal 

Welfare Act and is not ready for licensing at this time. The Applicant 

must wait 6 months from (insert date of failed 3rd PL Inspection) to 

reapply. The license fee will not be refunded or applied to the next 

application for licensure.”

o “You may appeal this finding in writing by (insert date which is 7 days 

after the issuance of the report)

o “Appeals should be addressed to: 

Dr. Elizabeth Goldentyer

APHIS Animal Care (AC)

U.S. Department of Agriculture

4700 River Road | 6D-03F

Riverdale, MD 20787”

o “OR emailed to: animalcareappeals@usda.gov”

o “Conducting regulated activities without a valid USDA license is a 

violation of the Animal Welfare Act.”

Failed 3rd PL Inspection Appeal

Inform the applicant that they may appeal all or part of the inspection 

findings to the Deputy Administrator. 

To file an appeal, the applicant must:

o Send a written statement contesting the inspection findings, and

o Include any documentation or other information in support of the appeal

The inspection appeal must be received by the Deputy Administrator within 

7 days of the date the applicant received the third prelicense inspection 

report.

Appeals should be addressed to: 

Dr. Elizabeth Goldentyer

APHIS Animal Care (AC)

U.S. Department of Agriculture

4700 River Road | 6D-03F

Riverdale, MD 20787

OR emailed to: animalcareappeals@usda.gov
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Photographs

Photographs must be taken during Prelicense Inspections under the following 

circumstances:

1. For an applicant who is not licensed and is applying for a new 3-year license:

o NCIs cited on the 3rd Prelicense Inspection since the NCI(s) may be 

appealed

2. For a licensee who is currently licensed and is now applying for a 3-year

license:

o Any Repeat, Critical, or Direct NCIs documented on the 1st and/or 2nd 

Inspection

o Any NCIs cited on the 3rd Inspection since the NCI(s) may be appealed

Relicensing

For a facility that was licensed previously and is in the process of being 

relicensed, conduct the relicensing inspection as detailed for a prelicense 

inspections with the following changes: 

• Only review the prelicense presentations that are applicable to that licensee, 

i.e. areas that the licensee had problems or NCIs in the past or identified on 

the current inspection

• Review other prelicense presentations that you believe would be beneficial 

for the licensee

• Inspection Type should be “Re-License”

• Designate NCIs as Directs, Criticals or Repeats as appropriate and take 

photographs

• Directs should be handled like a Direct on a Routine Inspection:

o A short correction date should be given. The following language should 

be used on the IR: “Correct by (date) or prior to your next schedule 

relicense inspection whichever comes first.” 

o A focused unannounced inspection must be conducted to check on the 

Direct 

• For statements on the Inspection Report, see below

• If the facility had a variance (e.g., perimeter fence, records), the variance 

continues to apply as long as the circumstances under which the variance 

was issued have not changed.
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4.19.7.1. Completion of the Relicensing Inspection Report 

No NCIs Identified – Relicensing Process Passed

• Complete an Inspection Report which must include the following statements:

o “No noncompliant items were identified during this relicense inspection.”

o “This is a (1st/2nd/3rd) Relicense Inspection for a Class (“A” / “B” / “C”) 

license. The inspection and exit briefing were conducted with the 

Applicant. The Applicant is ready to be licensed under the AWA.”

o “A copy of your license will be sent to you without any additional action 

on your part. If you have not received your license within 30 days, please 

contact the USDA at 970-494-7478.”

NCIs Identified – Relicensing Process NOT Passed

For the 1st or 2nd Relicense Inspection

• Complete an Inspection Report which must include the following statements:

o “This is a (1st/2nd) Relicense Inspection for a Class (“A” / “B” / “C”) 

license. The inspection and exit briefing were conducted with the 

Applicant.”

o “All items must be in compliance within (2 /1) more inspection(s) or by 

(enter date - 60 days counted from 1st Relicensing Inspection) or the 

Applicant will forfeit the license fee and must wait 6 months to reapply. 

Please contact your inspector to schedule your next Relicense 

Inspection.”

o “Regulated activity can continue under your existing USDA license until it 

expires.”

For the 3rd Relicense Inspection

• Complete an Inspection Report which must include the following statements:

o “This is a 3rd Relicense Inspection for a Class (“A” / “B” /“C”) license. The 

inspection and exit briefing were conducted with the Applicant.”

o “The Applicant is not currently in compliance with the AWA as 

documented above. You may appeal this finding in writing by (insert date 

which is 7 days after issuance of report).”

o “Appeals should be addressed to: 

Dr. Elizabeth Goldentyer

APHIS Animal Care (AC)

U.S. Department of Agriculture

4700 River Road | 6D-03F

Riverdale, MD 20787”

o “OR emailed to: animalcareappeals@usda.gov”
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o “Your existing license will expire and a new license will not be issued.

Conducting regulated activities without a valid USDA license is a violation 

of the Animal Welfare Act.”

PL Inspection Process Reminders 

• All Prelicense Inspections must be thorough and complete. There are no 

focused PL Inspections.

• All Prelicense Inspections should be completed using the Enhanced 

Prelicense Process (EPLP) Guidance. If guidance is not available for the 

specific species being inspected, existing guidance should be adapted and 

used as needed.

• All Prelicense Inspection Reports must be hand delivered. If hand delivery is 

not possible, discuss extenuating circumstances with your SACS.

• Prelicense presentations should be done prior to conducting the inspection 

of facility and whenever deemed appropriate during the prelicense process 

to help clarify any issues found during the inspection

• This is where the bar of compliance can be set, and future problems can be 

avoided

• Discuss optimal hours with the applicant and record the days/times in eFile
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4.20. Search Inspection

A search is an inquiry relating to possible unlicensed activity.

Subjects of Searches

Subjects of searches include, but are not limited to:

• Persons breeding and selling dogs, cats or pet-type animals wholesale or 

retail sight unseen

• Persons selling wild or exotic animals retail or wholesale 

• A non-registered research facility purchasing regulated animals

• Persons exhibiting regulated animals

• Persons using regulated animals for rides

• Involuntarily terminated licensees or registrants (e.g., canceled due to nonrenewal, suspended due to consent decisions and orders)

• Previously identified violators

Use good judgment to decide when you have made a reasonable effort to verify 

unlicensed activities.

Examples of possible ways to verify unlicensed activity are:

• Checking dealer, broker, carrier/handler records

• Checking newspaper advertisements

• Checking the internet

• Communicating with other inspectors

• Making phone calls

• Visiting the facility

Sources of Information

Sources of information include, but are not limited to:

• Advertisements

• Animal protection groups

• Anonymous tips

• APHIS personnel

NOTICE

If you have reason to suspect that an involuntarily terminated license/

registrant is continuing to operate without a license or registration, conduct a 

search within 60 days of the termination of the license, if possible.
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• City, county, or State agency

• Dog or exotic animal auction records

• General public

• Internet sites

• Newspaper/journal articles

• Another Federal agency

• State health certificates

• Whistle blower

Sources may provide information by the following methods:

• Email

• Letters

• Personal contact

• Phone calls

Information Follow-Up

Decide if the information supplied to the Animal Care program involves a 

regulated activity or animal.

If the information does not involve a regulated activity or animal:

• Discuss with the informant AWA regulated activities/animals

• Thank the informant for his/her interest in the welfare of animals

• Refer the informant to the appropriate office/agency, if known. Possible 

referral agencies include:

o U.S. Fish and Wildlife Service

o NIH-OLAW

o State wildlife agency

o Local animal control

o State or local humane society

o State animal welfare agency

• Take no further action

NOTICE

The informant does not have to give his/her name. However, if the informant 

does give his/her name, do not give out the person’s name in order to 

maintain confidentiality.
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If the information does involve a regulated activity or animal:

• Thank the informant for his/her interest in the welfare of animals

• Complete the top portion of a Search sheet. (See USDA, APHIS, Animal Care 

Search for Unlicensed Activity Worksheet)

• Determine if the information applies to a person in your territory

If the information applies to a person, business, or research facility not in your 

territory:

• Tell the informant that the facility is not in your area, but that you will 

forward the information to the AWO Field Office for distribution to the 

appropriate inspector

• Give the informant the AWO Field Office phone number for follow-up

• Forward the information (e.g., copies of records, invoices, sale bills) to your 

SACS for referral to the appropriate SACS

If the information applies to a person in your territory, conduct a search.

Preparing for the Search

Confirm whether the individual/business is already entered into eFile: 

• If the person does not already have a customer identification number (CID), 

request an ILA to assign one. You will need to provide all the relevant 

information to the ILA. 

• If the person already has a CID, review the relevant facility information

including inspection history, previous licenses, prior search results, or other 

activity (included being sent an application or unlicensed facility letter). 

Conducting the Search

Searches may be conducted:

• By phone

• By internet

• In person – If you have any concerns, contact the person by another method

Note: The inspector may request a background check of the person by the 

EMSSD Security Branch. Contact your SACS. 

Verify the information received by:

• Contacting the authorized representative

• Gathering additional information, such as:

o Newspaper or journal articles

o Classified ads

o Information off the internet
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o Internet web site addresses

If regulated activities are not being conducted, then complete a Search sheet 

and submit your findings to your SACS and AWO Field Office.

If regulated activities are being conducted, then:

• Explain to the owner or authorized representative that the activity requires a 

USDA license or registration

• Discuss with the owner or authorized representative all the pertinent 

portions of the AWA and Regulations and Standards

• Request a decision about the continuation of the regulated activity

• Give or have the AWO Field Office send an application packet to the 

authorized representative 

• If you give the person an application packet, let the AWO Field Office know

• Take photographs documenting the regulated activity if you can do so safely. 

This may include supporting documentation, such as, billboards or other 

public advertising, waybills, or broker records that you obtained from other 

sources.

• If the owner or authorized representative has not previously been contacted 

by Animal Care or licensed, offer to conduct a Courtesy Visit (See Courtesy 

Visits):

o Go through the facility thoroughly, and 

o Explain all NCIs and potential NCIs to the owner/authorized 

representative

• If the owner or business has previously been licensed/registered or received 

a letter or Application/Registration Packet:

o Advise the owner that he/she will be receiving an Inspection Report citing 

the conducting of regulated activity

o Complete an Inspection Report:

o Classify the inspection as “Routine”

o In the narrative, cite Section 2.1(a)(1) for conducting regulated activities 

without a license or Section 2.30(a) for conducting regulated activities 

without a registration for a research facility or Section 2.25(a) for 

conducting regulated activities without a registration for a 

transporter/intermediate handler, and describe the regulated activity

- State the following at the end of the Inspection Report: “No regulated 

activities may be conducted until USDA license/registration is 

obtained.” 

- Send the Inspection Report to him/her by regular and certified, return 

receipt mail
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4.20.4.1. No Courtesy Visit Conducted 

If the owner or authorized representative does not want a Courtesy Visit OR you 

decide not to conduct a Courtesy Visit for safety concerns:

1. Inform the owner or authorized representative that he/she or the business is 

noncompliant with the Animal Welfare Act by conducting a regulated activity 

without a license/registration

2. Take photographs documenting the regulated activity if you can do so safely

3. Give or have the AWO Field Office send an application or registration packet, 

if applicable, to the owner or authorized representative

4. Discuss how to proceed with your SACS

Post Search Procedures

After conducting a search, ALWAYS:

1. Complete a Search sheet

2. Enter the Courtesy Visit into eFile

3. Enter the Inspection Report into eFile, if applicable

4. Enter any photos taken of the regulated activity or supporting 

documentation into eFile

5. Submit the Search sheet with Inspection Report if applicable to your SACS for 

review

6. After approved by your SACS, upload a copy of the Search sheet into eFile

7. If conducting regulated activity was cited on an Inspection Report, discuss 

with your SACS if an enforcement action would be appropriate

Follow-Up Procedure

If an owner/business/research facility you contacted on a search was conducting 

a regulated activity and the owner or business has not applied for a license/ 

registration within 3-4 months, discuss with your SACS if you should revisit the 

facility to determine if a regulated activity is still being conducted.

If the person is no longer conducting a regulated activity:

• Complete a Search sheet documenting this fact

• Submit the Search sheet following the standard procedure

If the person/business/research facility is still conducting a regulated activity:

• If safe and appropriate, remind the authorized representative that a USDA 

license/registration is required to conduct this activity

• Document the regulated activity by either:
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o Conducting an inspection, if possible, or

o Completing another Search sheet

• Take photographs, if possible

• Discuss how to proceed with your SACS

On the Road Inspection

If you find an unlicensed exhibitor on-the-road, inform the exhibitor that:

• A USDA license is required for the activity he/she is conducting

• All applicable AWA Regulations and Standards must be met at all sites

• He/she cannot legally exhibit until licensed

Obtain the following information from the exhibitor:

1. Location of the home base or permanent facility which he/she returns to 

between tours

2. Animals currently housed at the home base or permanent site

3. Name of any other Animal Care inspectors that the exhibitor has been in 

contact with and the results of that contact

4. Ways to contact the exhibitor while on-the-road

5. An itinerary

If the exhibitor refuses to give you any information:

• Get vehicle license tag number, if possible, to obtain follow-up information

• Try to get contact information and itinerary from the manager, if applicable

• Discuss how to proceed with your SACS

NOTICE

The noncompliance cited for conducting regulated activities without a 

license/registration, should be designated as a “Repeat” noncompliance.
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4.21. Traveling Exhibitor Inspection

Each inspector should develop a consistent method of conducting inspections of 

traveling exhibitors that ensures a thorough and accurate inspection.

Home Site Inspection

A Traveling Exhibitor must have a home site (001). If animals are housed at the 

home site, the facility must meet all the applicable AWA Regulations and 

Standards for a permanent location.

If a Traveling Exhibitor uses a PO Box or other mail drop location as the home 

site, they must have another permanent location where animals can be 

inspected, especially for the Prelicense Inspection. 

If no one is home and/or available for an inspection at the home site, there is no 

itinerary showing all animals were traveling and it is during the exhibitor’s 

optimal hours if applicable, then an Attempted Inspection Report should be 

written. 

If animals are not housed at the home site, i.e., it is a business or mailing 

address:

• An inspection must still be conducted at this site 

• If the licensee is not at the home site, an authorized person should be 

designated by the licensee and available to conduct an inspection 

• At a minimum, records, such as the program of veterinary care and 

acquisition/disposition/animals on hand, should be available at the home site

• Note on the Inspection Report that no animals are housed at this facility and 

that it is a business/mailing address. For example: “No animals present at 

facility. This site serves as a mailing address.”

General Information

Inspections of traveling exhibitors are different from inspections at the home 

facility. However, all of the applicable AWA Regulations and Standards must be 

met.

If you become aware that a traveling exhibitor is, or will be, performing in your 

territory:

• Check eFile for the date and results of the last TRA inspection.

• Do not conduct an inspection if:

o An inspection has been conducted within 90 days, and 

o The inspection had no noncompliances, and

o There is no open complaint on the exhibitor

• If the traveling exhibitor was not inspected within 90 days and/or had a 
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noncompliance on the last TRA inspection, or there is an open complaint on 

the exhibitor, contact your SACS to determine if an inspection is needed

• Contact the home inspector or home SACS to see if there are any ongoing 

concerns or active complaints

Admission to the Venue

If the venue, e.g., theme park, State/county fair, Renaissance festival, or craft 

show has an admission gate:

1. Go to the admission gate/ticket window

2. Identify yourself in a professional manner

3. State the purpose of your visit

4. Show your USDA badge and ID

At most venues, you will not be required to pay admission. However, if an 

admission fee is requested, ask to speak to someone in management.

If you need to pay admission, contact your SACS for approval, then charge the 

admission fee on your Purchase MasterCard (preferable), or pay cash/personal 

credit card (you will be reimbursed).

Prior to conducting the actual inspection or immediately after your 

unannounced observation:

1. Contact the licensee/registrant or authorized representative

2. Introduce yourself in a professional manner

3. State the purpose for the visit

4. Show your USDA badge and ID

5. Provide a business card if appropriate

If you do not find anyone at the facility, follow procedures for an Attempted 

Inspection (see Attempted Inspections in Chapter 4).

NOTICE

Under certain circumstances, you may want to observe the exhibition, facility, 

or facility personnel prior to announcing your presence. If necessary, pay the 

entrance fee and you will be reimbursed. The observation should be done 

from areas accessible to the general public. Immediately after observing the 

exhibition/ facility/personnel, you must announce yourself to the 

licensee/registrant or facility representative and arrange to complete the 

inspection and address any findings that you observed prior to announcing 

yourself.
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Conducting the Inspection

• Prior to conducting the inspection:

• Contact the home inspector or the inspector who conducted the last TRA 

inspection if you have questions

• Review prior inventories

• In eFile, review past inspections, including photos if available, teachable 

moments, current enforcement actions, and contact information

4.21.4.1. General Inspection Requirements

When inspecting a traveling exhibitor, some recommended items to evaluate/ 

observe include, but are not limited to:

• A performance/act

• Adequate shelter and shade for animals housed outdoors

• Availability and use of exercise areas

• Chained or tethered animals

• Enclosures for adequate space during travel and at the temporary location

• Feeding schedules

• Food preparation and storage areas

• Fresh meat if required. Ask about:

o Sources of the meat while on the road

o Storage

o Method(s) of thawing

• Handling of the animals – observe: 

o Handling before contacting the authorized representative if needed

o Any direct contact activity allowed with the public, such as feeding or 

photos 

• Health and well-being of all the animals, such as:

o Alertness and activity level

o Behavior

o Foot and hoof care

o Normal appearance

NOTICE

Food deprivation may not be used for training.
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o Presence of wounds

• If you have concerns about an animal, ask to see the animal up close, if you 

can do so safely

• Loading and unloading of animals

• Qualifications and training of the animal handlers

• Records (see Records)

• Security measures to protect the animals and the public, such as:

o Barrier fences or electric fences

o Night security

o Uniformed attendants

• Source and quality of the drinking water to make sure it is potable

• Sufficient number of employees to provide for the animal’s care

• Transport vehicles (see Transport Vehicles)

• Veterinary care and vet records (see Veterinary Care)

For animals in transit, see Animals in Transit.

4.21.4.2. Dogs and Cats

If the dogs or cats live loose in the licensee’s traveling home, such as a house 

trailer or camper:

• Ask how the dogs/cats are transported in the conveyance to ensure that the 

travel Standards are being met.

• Check the room(s) that the dogs/cats live in to ensure that it meets all 

primary enclosure Standards.

• Check for required records and ID

4.21.4.3. Wild and Exotic Animals

• When inspecting wild and exotic animals, ensure that:

• All animals in the enclosure are able to make normal postural adjustments 

(stand in an upright position, turn around, and lie down with limbs extended 

in a normal manner without obstruction from enclosure sides or having to 

extend feet through bars or feeder doors)

CAUTION

Be alert and cautious around the animals. Remember that big cats spray, 

nonhuman primates spit and throw feces, and animals may be able to get 

their legs, paws/feet, trunk, etc., through the bars of their enclosures.
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• Animals that normally engage in occasional vertical postures, such as bears 

and many felines, have sufficient vertical space available to accommodate 

these postures 

• The primary enclosures for other animals should have adequate space for 

each animal to express all non-injurious species-typical:

o Behaviors

o Postures/movement (such as grooming) 

o Social adjustments

Some information to remember when inspecting certain species:

• Baboons and chimps have sexual swellings that may resemble tumors.

• Camels:

o When males become excited, they may blow up a sac-like extension of 

the soft palate into a red “balloon” which hangs out from the corner of 

their mouth.

o Males in a “musth/rut” may:

- Dribble urine

- Drool, slobber, and froth at the mouth

- Have rough/scaly hair coats

- Lose a significant amount of weight

- Make gurgling sounds

• Large cats–females in heat:

o Become very vocal

o Roll around

o Urine spraying behavior (all big cats)

• Tethered hoof stock should have tethers of sufficient length and 

arrangement to be able to comfortably lie down, get up, self-groom, and 

move about within a reasonable distance.

4.21.4.4. Veterinary Care

When inspecting traveling exhibitors, check for the following:

• The exhibitor has an attending veterinarian

• If the attending veterinarian is part-time, there is a formal arrangement

• Environmental enhancement plan for nonhuman primates, which may need 

to be different than the plan at the home facility

• Exercise plan for dogs while in travel status, which may need to be different 

than the exercise plan at the home facility
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• Health and well-being of the animals

• Health certificates, if required

• Required medical records for marine mammals

4.21.4.5. Records

A traveling exhibitor should have the applicable required records with him/her 

on the road. However, if the records are at another site or location, it is 

acceptable for the records to be emailed or faxed to the site of the inspection 

during the inspection if possible. Otherwise, the exhibitor can email or fax the 

records to the inspector within 48 hours to be in compliance.

If the required records are not available and not received by the inspector within 

48 hours, cite as a noncompliance under the appropriate Section.

A traveling exhibitor must have all the appropriate records for the regulated 

animals for up to 1 year from the disposal or euthanasia of the animals.

The following records, when applicable, must be available for review during an 

inspection on the road, as required by the Regulations and Standards:

• Acquisition records or a record of animals on hand for all regulated animals 

present

• Disposition records for all regulated animals that have left the current tour 

since it began, or died or been euthanized while on the road 

• Exercise plan for dogs

• Health certificates for dogs, cats, nonhuman primates and marine mammals, 

if required

• Individual medical records for marine mammals

• Necropsy records for marine mammals

• Nonhuman primate environmental enhancement plan

• Program of veterinary care appropriate for the animals being exhibited

• Water quality records for marine mammals

4.21.4.6. Transport Vehicles

Inspect transport vehicles for:

• Cleanliness

• Condition of the floor, i.e., rotting areas which could give way and/or allow 

entry of exhaust fumes

NOTICE

Copies of the original records are acceptable.
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• Food storage areas

• Separation of species while in transit

• Space and height for the species transported

• Structural strength, such as:

o Bent or warped surfaces

o Loose fittings or grates

o Protruding edges

• Vehicle safety features, such as:

o Door latches and locks

o Good tires

o Proper hitches

o Tires rated for the weight load carrying

o Vehicle rated for the weight load carrying

• Ventilation and temperature when doors are closed

• Working temperature control systems, such as heaters, fans, and air 

conditioners

• Accessibility to the animals as needed

• Adequate barriers, protection, and security of the transport vehicle/trailer to 

keep the public from getting close to the animals while the vehicle is 

stopped, such as at a motel or restaurant. This is especially important for 

trailers with large openings, such as stock trailers.

Animals in Transit

When in transit, all regulated animals must be housed in enclosures that meet 

the transportation requirements for that species.

An animal is considered “in transit” when it is moving in a conveyance from:

• The home facility to a temporary location

• A temporary location (exhibition venue) to another temporary location

• A temporary location to the home facility

Stopping overnight, such as at a hotel/motel, or stopping for short rest periods 

and food breaks for the drivers, handlers, and other people accompanying the 

animals is still considered “in transit.”

Animal Races

Examples of animals used for staged animal races include, but are not limited to:

• Camels
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• Gerbils

• Hamsters

While conducting your inspection, areas to pay special attention to include, but 

are not limited to:

• Individual tolerances of the animals

• Length of race for species being raced

• Methods used to encourage the animals to run 

• Number of races per day for each animal

• Rest periods for animals between races

• Species and age of animals being raced

Animal Rides

See Animal Rides in this Chapter.

Circus and Performing Animal Inspections

Some areas to pay special attention to include, but are not limited to:

• Amount of time animals perform and are rested

• Handling of the animals

• Housing for animals between shows

• Methods or types of restraints used to control the animals

• Procedure for moving animals from housing to the performance area

• Procedure in the event of an animal escape or attack

• Public barriers

• Training and handling experience of the handlers and employees

NOTICE

Professional dog races, such as greyhound races, field trials, and tracking 

events and races with farm animals such as pigs are exempt.

NOTICE

If you have questions, or are unsure about a situation, use your professional 

judgment and/or call your SACS.

NOTICE

Drugs may not be used to control the animals.
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• Transport enclosures and transportation vehicles

• Type and safety of public contact with dangerous animals

Circuses may be:

• Covered under one exhibitor’s license

• Composed completely of individually licensed exhibitors who work for the 

circus. In this case, a separate Inspection Report must be completed for each 

licensee.

• Composed of a combination of a licensed circus and individually licensed 

exhibitors. In this case:

o Complete one Inspection Report for the licensed circus itself and include 

all the regulated animals covered under the circus’s license, and

o Complete separate Inspection Reports for each individually licensed 

exhibitor

4.21.8.1. Observing the Circus or Performing Animal Show

Prior to announcing your presence, you may want to watch an actual 

performance to observe the handling of the animals and the types of acts/tricks 

the animals are performing.

Make a notation on the Inspection Report, whether you watched the 

performance or not.

• Pre-performance activities involving the public

• Procedure for moving animals in and out of the rings

• Space requirements for the animals, i.e., are animals housed in their 

transport enclosures? If so, do these enclosures meet the space 

requirements when not in actual transit?

NOTICE

If you have questions or are unsure about a situation, use your professional 

judgment and/or call your SACS.

NOTICE

It is important to know which exhibitor’s license covers the particular animal 

you are inspecting. It is common for exhibitors/animal acts to travel with 

more than one circus in a touring season. If you have questions or are unsure 

about a situation, call your SACS.

NOTICE

Drugs may not be used to control the animals.
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• Vertical space for animals that require it, such as bears, large cats, and 

nonhuman primates

• Check substrate where animals are housed (dirt, concrete, asphalt) for:

o Temperature as concrete and asphalt may get very hot

o Sufficient amount of bedding 

Petting Zoos

See Petting Zoo Inspection.

Photo Shoots

See Photo Shoot Inspection.

Inspection Reports

When entering an Inspection Report for a traveling exhibitor not at his/her home 

site, ensure that:

• You use the “traveling-on-the-road” (TRA) site designation in eFile

• If the licensee does not have a TRA site already in eFile or the TRA site is not 

active, follow the procedures for Action to Take When a Person, Facility, or 

Site is Not in the eFile Database

• If the licensee has more than one TRA site, use the correct TRA site if it is in 

eFile, such as the “Blue Unit” or the “Red Unit”

• In the narrative section, include:

o Name of the venue, e.g., Douglas County Fair, and

o Location of the inspection, i.e., city and State, and 

o Name of the circus, unit, or group, if applicable, and

o If there was a show/performance, if you did or did not watch the 

show/performance

o Names of the elephants inspected if applicable

• Email a copy of the Inspection Report to the home inspector or inform the 

home inspector that you conducted a TRA inspection

Itinerary

All traveling exhibitors must submit an itinerary. For details, see Traveling 

NOTICE

Never enter a pen or enclosure unless absolutely necessary and the animal(s) 

are secured.
--- Animal Care Inspection Guide ---

Savedate 12/7/2021 9:38 AM Specific Types of Inspections 4-88

Petting Zoo Itinerary. 

Check to see if the facility has submitted an itinerary for future exhibitions, 

especially if there were NCIs on the Inspection Report.
--- Animal Care Inspection Guide ---

Savedate 12/7/2021 9:38 AM Specific Types of Inspections 4-89

4.22. Wild/Exotic Animal Auction Inspection

All regulatory requirements for wild/exotic animal auctions must be met by:

1. Operator of the Auction, and

2. Consignor of the animal if the consignor is licensed or is required to be 

licensed

Licensing Requirements

Persons selling wild or exotic animals for covered purposes must be licensed.

4.22.1.1. Operators of the Auction

Operators of the wild/exotic animal auction must have a Class B license.

4.22.1.2. Consignors of Wild/Exotic Animals to the Auction

Some consignors of animals to the auction may require a USDA license:

• Consignors of wild/exotic animals clearly sold only for covered purposes 

must have a license (See examples in column 3 in the table below)

• Consignors of animals not regulated by the AWA do not require a license (See 

examples in column 1 in the table below)

• Consignors of animals that may be used for covered or non-covered 

purposes may require a license. (See examples in column 2 in the table 

below). The inspector will need to determine either at the auction or after 

the auction if the animal was sold for a covered purpose. This should be 

discussed with the SACS. 

Never need a license May need a license Always need a license

Birds

Horses, donkeys, mules 

Reptiles

Farm-type animals used for 

agricultural purposes

Alpacas and llamas Farm-type 

animals not used for 

agricultural purposes

*Foxes and mustelids 

Wild or exotic hoofstock 

Opossums

Rabbits

Squirrels

Raccoons

Zebras Camels

Common pet-type mammals

Cavies

Coatis Kinkajous

Wild/exotic canids Megaherbivores 

(elephants, rhinos, hippos, giraffes) 

Primates 

Wallabies and kangaroos

*Wild/exotic cats 

Bears

Pocket pets

*Animals used for fur, food or hunting are exempt.
--- Animal Care Inspection Guide ---

Savedate 12/7/2021 9:38 AM Specific Types of Inspections 4-90

Regulatory Responsibilities

Care of the animals while at the auction is the responsibility of:

• Consignor (if the consignor is licensed or required to be licensed), and

• Operator of the auction 

All regulatory requirements for the animals’ care, including the provision of 

veterinary care when necessary, must be met. 

The auction’s responsibility does not extend to animals kept in transport vehicles 

in auction parking lots, etc. These animals are the sole responsibility of the 

persons transporting them. 

Every covered animal that the auction consigns will be regulated while it is 

within the auction facility.

Inspection Procedures

4.22.3.1. Animal Enclosures

Animals may be housed at an auction ground in transport enclosures. 

These animals are considered to be “in transit” and may remain in these 

enclosures while at the auction as long as:

• All the enclosure requirements from the Transportation Standards for the 

appropriate species are met or exceeded

• An animal is not showing obvious physical distress, including signs of

behavioral stress, physical harm or unnecessary discomfort while held for 

long periods in a transport enclosure

o If an animal is showing signs of distress, harm or discomfort, the auction 

owner, and the consignor if licensed should be cited for a handling 

violation

• Incompatible animals are not held in the same enclosure or close to other 

animals that may cause them stress

4.22.3.2. Handling of Animals

Auction employees must be properly trained and experienced to handle 

animals during a sale. 

If the auction does not have any personnel qualified to handle certain animals, 

those animals should only be handled by the consignor, assuming that person is 

qualified. 

Transferring from a transport enclosure to another larger enclosure can be 

stressful for many animals. Transfers must be accomplished by persons trained 

in making such transfers. There can be disastrous results if animals are moved by 

untrained and/or inexperienced persons. 
--- Animal Care Inspection Guide ---

Savedate 12/7/2021 9:38 AM Specific Types of Inspections 4-91

4.22.3.3. Public Exhibition of Animals

Animals are often kept on display for public viewing during an auction. In fact, 

many members of the public go to auctions simply to see the animals with no 

intention of bidding on them. 

Operators of auctions must:

• Utilize appropriate barriers and/or distance to ensure the safety of the 

animals and public, and

• Have a sufficient number of readily identifiable attendants present at all 

periods of public contact with the animals
--- Animal Care Inspection Guide ---

Savedate 12/7/2021 9:38 AM Record-Keeping for Licensees 5-1

Record-Keeping for Licensees

Contents

5.1. Records 5-2

Required Dealer and Exhibitor Records 5-2

Computerized Records for Dogs and Cats 5-2

Health Certificates for Dogs, Cats and Nonhuman Primates 5-3

Dealer and Exhibitor Records That Are Not Required 5-4

Puppy and Kitten Records and Identification 5-4

DISCLAIMER

The Animal Welfare Inspection Guide is intended to be a reference document to assist the 

inspector. The Inspection Guide does not supersede the Animal Welfare Act (AWA), the AWA 

Regulations and Standards, AC policies and other guidance, the Required Inspection 

Procedures, standard procedures, or the inspector’s professional judgment. All inspection 

decisions must be justified by applicable sections of the AWA and/or the AWA Regulations 

and Standards.
--- Animal Care Inspection Guide ---

Savedate 12/7/2021 9:38 AM Record-Keeping for Licensees 5-2

5.1. Records

A dealer, exhibitor, or research facility must have all required records for 

regulated animals purchased or otherwise acquired, owned, held, or in his/her 

possession or control, transported, or disposed of.

Required Dealer and Exhibitor Records

Dealers and exhibitors must have the following records, when applicable, for 

review:

• Acquisition and disposition records [2.75(a)(1), 2.75(b)(1), 2.76(a)]

• Program of Veterinary Care for dogs for any facility with dogs [3.13(a)]

• Program of Veterinary Care for all animals other than dogs when using a 

part-time attending veterinarian [2.40]

5.1.1.1. For Dogs and Cats

For dogs and cats, the following information is required:

• Certification for procurement of animals [2.132(d)]

• Exercise plan for dogs [3.8]

5.1.1.2. For Nonhuman Primates (NHP)

For nonhuman primates, the following information is required:

• Environmental enhancement plan for nonhuman primates [3.81]

5.1.1.3. For Marine Mammals

For marine mammals, the following information is required:

• Approved water and power emergency contingency plans for marine 

mammals [3.101(b)]

• Documentation of training of attendants or employees working with marine 

mammals [3.108(b)]

• Medical records for marine mammals [3.110(d)]

• Necropsy records for marine mammals [3.110(g)(1-2)]

• Water quality records for marine mammals [3.106(b)(3)]

Computerized Records for Dogs and Cats

A licensee who uses a computerized record-keeping system must request a 

variance from the requirement to use APHIS Form 7005 – Record of Acquisition 

of Dogs and Cats on Hand and/or APHIS Form 7006 – Record of Disposition of 

Dogs and Cats in Appendix A. [2.75(a)(2)]
--- Animal Care Inspection Guide ---

Savedate 12/7/2021 9:38 AM Record-Keeping for Licensees 5-3

Each licensee with a computerized record-keeping system must request his/her 

own variance.

The variance request must meet the following: [2.75(a)(2)(i)]

• Be in writing

• Be sent to the Fort Collins AWO office

• Contain a description of the computerized record-keeping system to be used 

• Explain why the APHIS Form 7005 or 7006 is unsuitable to use

If the variance is denied, the licensee may request a hearing for the purpose of 

showing why the variance should not be denied. The denial remains in effect 

until a final legal decision is rendered. [2.75(a)(2)(ii)]

The inspector may do the following:

• Review records on the computer screen, or 

• Review a hard copy

• If the inspector is unable to review the records for proper inspection, cite it 

on the Inspection Report under section 2.126(a)(2).

Health Certificates for Dogs, Cats and Nonhuman Primates 

• A licensed veterinarian must execute and issue health certificates for dogs, 

cats and nonhuman primates transported by an intermediate handler or

carrier in commerce or delivered by [2.78]:

• A dealer, exhibitor, operator of an auction sale, broker, or 

• Department, agency, or instrumentality of the United States, or

• Any State or local government

o This includes interstate and international transportation, as well as other 

transportation which affects commerce. 

NOTICE

Unless approved by AW Operations, records must be viewable during the 

inspection. Providing physical media (e.g., USB drive, CD) without a method 

to view its content is insufficient. 

NOTICE

This health certificate requirement excludes any person who arranges for 

transportation or transports animals solely for the purpose of breeding, 

exhibiting in purebred shows, boarding (not in association with commercial 

transportation), grooming, or medical treatment, and is not otherwise 

required to obtain a license. [2.1(a)(3)(v)]
--- Animal Care Inspection Guide ---

Savedate 12/7/2021 9:38 AM Record-Keeping for Licensees 5-4

5.1.3.1. Responsibility for Health Certificates

The dealer/exhibitor/broker must provide a valid health certificate whenever a 

registered carrier or intermediate handler picks up a cat, dog, or NHP for 

transport in commerce whether being transported within or out of State. 

[2.78(a)]

The transporter may not receive an animal for transport without a valid health 

certificate whether the animal is being transported within or out of State. The 

transporter must keep and maintain a copy of the health certificates for one 

year. [2.77(b), 2.80(b)]

Dealer and Exhibitor Records That Are Not Required

The following non-required records may be helpful to dealers and exhibitors:

• Documentation of preventive medical treatments

• Documentation of training for all handlers of dangerous animals

• Emergency plan for dealing with animal attacks or escapes

• Noncommercial diet approval for large felids

Puppy and Kitten Records and Identification

Breeders are required to identify and maintain records on all puppies/kittens 

born at the facility [2.50]. They have the option to maintain these records on the 

APHIS 7005 form OR on cage cards. [2.75]

Breeders may choose to identify their puppies/kittens less than 16 weeks of age 

by any of the following methods: 

• An official tag, or

• An official tattoo, or

• A plastic type collar, or

• A microchip (see below), or

• A cage card (see below)

If a microchip is used:

• The microchip scanner must be readily available for the inspector, and

• The location of the microchip must be consistent from animal to animal, and

• The microchip number must be listed on the animal identification records 

These records are not specifically required by the AWA Regulations and 

Standards, except where applicable for dogs and marine mammals. A lack of 

any of these records or inadequacy of these records may not be cited as a 

noncompliance, except as required for dogs and marine mammals.

NOTICE
--- Animal Care Inspection Guide ---

Savedate 12/7/2021 9:38 AM Record-Keeping for Licensees 5-5

If a cage card is used:

• The puppies/kittens must be maintained as distinct litters at the facility 

where born, and

• The cage card must be attached to the outside of the enclosure, and

• Cage cards must be completed as soon as possible, preferably one or two 

days after each animal's birth, and

• Must include an individual ID number for each puppy or kitten, and

• The cage card may only be used as identification until the puppies/kittens are 

sold or moved from the facility where they were born or reach 16 weeks of 

age, whichever comes first, and

• If the cage card is used for both ID and record keeping purposes, it must be 

retained for one year after use

If the breeder uses the APHIS 7005 for puppy records and a cage card to identify 

puppies/kittens up to 16 weeks of age, the cage card must contain the following:

• Licensee’s USDA certificate number

• The letters “USDA”

• Unique number identifying each puppy/kitten

If a facility uses a cage card to satisfy both the records requirement and the ID 

requirement (weaning to 16 weeks of age), the cage card must contain the 

following:

• Licensee’s USDA certificate number

• Unique number identifying each puppy/kitten

• Date of birth of the litter

• Dam’s ID information

• A description of each puppy, which includes the following.

o Breed

o Sex

o Color

o Distinctive markings

• Date of disposition, death, or euthanasia

NOTICE

Unweaned puppies/kittens do not require individual ID while they are 

maintained as a litter with their dam in the same primary enclosure, provided 

the dam is individually identified. 
--- Animal Care Inspection Guide ---

Savedate 12/7/2021 9:38 AM Veterinary Care Requirements for Licensees 6-1

Veterinary Care Requirements for 

Licensees

Contents

6.1. Attending Veterinarian 6-2

Criteria 6-2

Multiple Attending Veterinarians 6-2

Veterinary Authority 6-3

Responsibilities 6-3

Health Certificates and Other Records that must be Prepared or 

Issued by Veterinarians 6-5

6.2. Written Program of Veterinary Care 6-7

Requirements for Dogs [3.13(a)] 6-7

Requirements for Animals Other than Dogs 6-8

6.3. Records 6-10

Required Records 6-10

Non-Required Information 6-13

Traveling Exhibitors 6-13

6.4. Inspection Guidance 6-14

General Information 6-14

Adequate Veterinary Care 6-14

Guidance for Communicating with the Attending Veterinarian 6-16

Recognition of Pain and/or Distress 6-18

Medication and Medical Supplies 6-20

Surgeries and Specialized Surgical Procedures 6-23

Euthanasia Guidance for Inspections 6-24

Additional Requirements for Inspecting Dogs 6-26

6.5. Documentation of Veterinary Care NCIs 6-28

Citing Section 2.40(b)(2) or 2.40(b)(3) 6-28

This Chapter applies to licensees only. For veterinary care requirements for 

Research Facilities, see Chapter 7.

DISCLAIMER

The Animal Welfare Inspection Guide is intended to be a reference document to assist the 

inspector. The Inspection Guide does not supersede the Animal Welfare Act (AWA), the AWA 

Regulations and Standards, AC policies and other guidance, the Required Inspection 

Procedures, standard procedures, or the inspector’s professional judgment. All inspection 

decisions must be justified by applicable sections of the AWA and/or the AWA Regulations 

and Standards.
--- Animal Care Inspection Guide ---

Savedate 12/7/2021 9:38 AM Veterinary Care Requirements for Licensees 6-2

6.1. Attending Veterinarian

A licensee must have an attending veterinarian (AV) to provide adequate 

veterinary care to his/her animals [2.40(a)].

An attending veterinarian is defined as a person who has:

• Graduated from an AVMA-accredited veterinary school, has a certification 

from the AVMA if a foreign veterinary graduate, or has equivalent formal 

education as determined by the Administrator

• Received training and/or experience in the care and management of the 

species being attended, and

• Has direct or delegated authority for activities involving animals

Criteria

A licensee must:

• Employ an attending veterinarian under formal arrangements [2.40(a)(1)]

• If the attending veterinarian is part-time or has a consultant arrangement, 

the formal arrangement must include [2.40(a)(1)]:

o A written program of veterinary care (PVC) and

o Regularly scheduled visits to the premises

• If a licensee enters into a formal arrangement with a new part-time 

attending veterinarian or consultant, the attending veterinarian or consultant 

must:

o Prepare a PVC, or

o Adopt the licensee's existing PVC

• Assure the attending veterinarian has appropriate authority [2.40(a)(2)] 

• Communicate to the attending veterinarian timely and accurate information 

on the health, behavior, and well-being of the animals [2.40(b)(3)]

Multiple Attending Veterinarians

In some circumstances a facility may use more than one veterinarian, or more 

than one attending veterinarian. For example, a facility may use one 

veterinarian with specialized knowledge and experience for all nonhuman 

primates and another veterinarian for all other species present at the facility. 

There must be one Attending Veterinarian who is responsible for the overall 

veterinary care decisions for the facility.
--- Animal Care Inspection Guide ---

Savedate 12/7/2021 9:38 AM Veterinary Care Requirements for Licensees 6-3

Veterinary Authority

The AWA Regulations require the licensee to assure the attending veterinarian 

has the appropriate authority to [2.40(a)(2)]:

• Ensure adequate veterinary care

• Oversee the adequacy of other aspects of animal care and use

The duties performed by the attending veterinarian to ensure compliance with 

the Regulations are ultimately the responsibility of the licensee, and the licensee 

must provide the attending veterinarian with adequate authority to carry out 

his/her functions. 

Responsibilities

The attending veterinarian under the authority given to him/her by the licensee 

must:

• Ensure the provisions of adequate veterinary care to the licensee’s animals 

[2.40(a)]

• Conduct regular visits to the premises, if the attending veterinarian is parttime or a consultant who is the attending veterinarian [2.40(a)(1)]

• Approve the facility’s practices as required by the Standards listed below

6.1.4.1. Dogs and Cats

Approval of the attending veterinarian is required for the following:

• Housing of dogs and cats in indoor facilities or the sheltered part of sheltered 

facilities where the ambient temperature falls below 50 o

F for those animals 

who are not acclimated to or cannot tolerate lower temperatures, such as 

[3.2(a) and 3.3(a)]:

o Short haired

o Sick

o Young or aged

o Infirm

• Outdoor housing of dogs and cats in the following categories [3.4(a)(1)]:

o Dogs/cats not acclimated to temperatures prevalent in the area/region

o Breeds that cannot tolerate the prevalent temperature extremes

o Sick, infirm, aged, or young dogs/cats

• Exercise plan for dogs [3.8]

• Exercise for dogs – Non-group housing of a dog(s) over 12 weeks of age if in 

the opinion of the attending veterinarian, group housing would adversely 

affect the health or well-being of the dog(s) [3.8(b)(2)]
--- Animal Care Inspection Guide ---

Savedate 12/7/2021 9:38 AM Veterinary Care Requirements for Licensees 6-4

• Exemption to the exercise requirement for a dog(s) [3.8(d)(1)]

6.1.4.2. Nonhuman Primates (NHPs)

Approval of the attending veterinarian is required for the following:

• Ambient temperature of the sheltered portion of sheltered housing facilities 

for NHPs [3.77(a)]

• Outdoor housing of NHPs [3.78(a)]

• Outdoor housing of NHPs with shelters that do not provide heat to prevent 

the ambient temperature from falling below 45oF [3.78(b)]

• Singly housed NHPs that are not able to see/hear other NHPs [3.81(a)(3)]

• Maintenance of NHPs in restraint devices for health reasons [3.81(d)]

• Statements of exemptions from participation in the environmental 

enhancement plan for individual NHPs [3.81(e)(1)]

• Restriction of water for NHPs [3.83]

• Approval of no food or water for NHPs during transport by a carrier or 

intermediate handler [3.86(c)]

In addition, facilities must follow any direction of the attending veterinarian 

concerning:

• Ambient temperature of indoor housing facilities for NHPs [3.76(a)]

• Relative humidity level of indoor housing and the sheltered portion of 

sheltered housing facilities for NHPs [3.76(b) and 3.77(b)]

• Ambient temperature in mobile or traveling housing facilities for NHP 

[3.79(a)].

• Environmental enhancement plan for NHPs. The plan must also be in 

accordance with currently accepted professional standards and address as 

appropriate [3.81] (Optional APHIS Form 7050 may be used.):

o Social grouping [3.81(a)]

o Isolation of NHPs that have or are suspected of having a contagious 

disease [3.81(a)(2)]

o Determination of compatibility of NHPs for social housing [3.81(a)(3)]

o Special considerations for NHPs requiring special attention, including 

[3.81(c)]:

- Infants and young juveniles

- NHPs showing signs of psychological distress

- Individually housed NHPs that cannot see/hear their own or 

compatible species

- Great apes weighing over 110 lbs. 
--- Animal Care Inspection Guide ---

Savedate 12/7/2021 9:38 AM Veterinary Care Requirements for Licensees 6-5

6.1.4.3. Marine Mammals (MM)

Approval of the attending veterinarian is required for the following:

• Statement of exemptions to MM housing requirements, including [3.104(a)]:

o Housing in smaller than required enclosures for nonmedical training, 

breeding, or holding for more than 2 weeks

o Housing in smaller than required enclosures for transfer for more than 1 

week

• Feeding MM less than once per day [3.105(a)]

• Application of insecticides and other such chemical agents in primary 

enclosures housing MM [3.107(d)]

• Approval for the single housing of social MM [3.109]

• Approval to house newly acquired MM with resident animals [3.110(a)]

• Holding of MM in a medical treatment or medical training enclosure that 

does not meet the minimum space requirements for more than 2 weeks 

[3.110(b)]

• Procedure for cleaning and/or sanitizing an enclosure which has housed a 

MM with an infectious or contagious disease [3.110(c)]

• Transport plan for transport of a MM lasting more than 2 hours in duration 

[3.116(a)]

In addition, the frequency of feeding for a MM in transit must be as often as 

necessary and appropriate for the species involved or as determined by the 

attending veterinarian [3.115(b)].

6.1.4.4. Other Animals

Procedures for sanitizing pens or runs using gravel, sand or dirt which had 

housed a Subpart F animal with an infectious or transmissible disease when 

necessary as directed by the attending veterinarian. [3.131(b)]

Health Certificates and Other Records that must be Prepared 

or Issued by Veterinarians

A licensed veterinarian must execute and issue health certificates for dogs, cats 

and nonhuman primates transported by an intermediate handler or carrier in 

commerce or delivered by [2.78]:

NOTICE

If you, the inspector, have a concern with the directions, instructions, or 

guidance the licensee has received from the attending veterinarian, discuss 

your concerns with your SACS.
--- Animal Care Inspection Guide ---

Savedate 12/7/2021 9:38 AM Veterinary Care Requirements for Licensees 6-6

• A dealer, exhibitor, operator of an auction sale, broker, or 

• Department, agency, or instrumentality of the United States, or

• Any state or local government

o This includes interstate and international transportation, as well as other 

transportation which affects commerce. 

• The attending veterinarian must prepare marine mammal necropsy reports 

[3.110(g)(1)]

• The attending veterinarian must sign health certificates for transport of 

marine mammals [3.112(a)]

• The attending veterinarian must execute temperature acclimation 

certificates for transport of marine mammals [3.112(c)]

NOTICE

This health certificate requirement excludes any person who arranges for 

transportation or transports animals solely for the purpose of breeding, 

exhibiting in purebred shows, boarding (not in association with commercial 

transportation), grooming, or medical treatment, and is not otherwise 

required to obtain a license. [2.1(a)(3)(v)]
--- Animal Care Inspection Guide ---

Savedate 12/7/2021 9:38 AM Veterinary Care Requirements for Licensees 6-7

6.2. Written Program of Veterinary Care

A licensee with dogs that has a full-time, part-time or consultant attending 

veterinarian (AV) must have a signed, written Program of Veterinary Care 

(PVC). [3.13(a)]

A licensee with animals other than dogs that has a part-time or consultant 

attending veterinarian (AV) must have a written Program of Veterinary Care 

(PVC). [2.40(a)(1)] 

Requirements for Dogs [3.13(a)]

Each dealer and exhibitor with dogs must have and follow an appropriate 

program of veterinary care that is:

• Developed, and

• Documented in writing, and

• Signed by the Attending Veterinarian (full-time, part-time or consultant)

The written PVC must be:

• Kept and maintained by the licensee, and

• Made available for APHIS inspection

In addition to addressing the general requirement for adequate veterinary care 

as required in Section 2.40, the written Program of Veterinary Care for dogs 

must include:

• Regularly scheduled visits, not less than once every 12 months, by the AV to 

all premises where dogs are kept to assess and ensure the adequacy of 

veterinary care

• Complete physical examination from head to tail of each dog by the AV, not 

less than once every 12 months, as follows:

o If the licensee has had the dog for 12 months, it must have had a physical 

exam during those 12 months 

o If the licensee keeps a puppy born on the premises, it must have a 

physical exam before it is 12 months old

o If the licensee buys a breeder, it must have a physical exam within the 

first 12 months of ownership, and every 12 months thereafter

NOTICE

The use of the APHIS Form 7002 – Program of Veterinary Care and/or the 

APHIS Form 7002a – Program of Veterinary Care for Dogs (see Appendix A) 

is not required. However, these are useful tools to ensure that all the 

requirements are met.
--- Animal Care Inspection Guide ---

Savedate 12/7/2021 9:38 AM Veterinary Care Requirements for Licensees 6-8

• Vaccinations for contagious and/or deadly disease of dogs in accordance with 

a schedule approved by the AV, including but not limited to:

o Rabies

o Parvovirus

o Distemper

• Sampling and treatment for parasites and other pests in accordance with a 

schedule approved by the AV, including but not limited to:

o Fleas

o Worms

o Coccidia

o Giardia

o Heartworm

• Preventive care and treatment to ensure:

o Healthy and unmatted hair coats

o Properly trimmed nails

o Clean and healthy:

- Eyes

- Ears

- Skin

- Teeth

Medical records must be maintained for dogs. See Section 6.3.1.1.1. 

Requirements for Animals Other than Dogs

The written program of veterinary care must: [2.40(a)(1)]

• Describe the facility's veterinary care plan

Topics for the written program of veterinary care that may be helpful in 

maintaining compliance (but are not regulatory requirements for a written PVC) 

include but are not limited to:

NOTICE

The following are not required by the Regulations:

• Use of the APHIS Form 7002 – Program of Veterinary Care (see Appendix A)

• The information listed in the APHIS Form 7002

• A signature of the attending veterinarian on the program of veterinary care 
--- Animal Care Inspection Guide ---

Savedate 12/7/2021 9:38 AM Veterinary Care Requirements for Licensees 6-9

• Vaccinations (species, juveniles vs. adults, list of vaccines, route, schedule of 

when they are to be given, and whether they are to be given by the licensee 

or the attending veterinarian)

• Parasite control (ectoparasites, blood parasites, intestinal parasites –

including required testing intervals, drugs to be used for prevention and 

treatment with ages of animals, dosages, route, and frequency)

• Detailed description of emergency care availability and contact information

• Detailed description of appropriate euthanasia to be used (including any 

personnel authorized to perform euthanasia and the method)

• Detailed description of capture and restraint methods. If the PVC includes 

more than one method, it is helpful to include a detailed description of all 

capture and restraint methods a facility might use.

• Treatment protocols that the attending veterinarian has pre-approved for 

the licensee or registrant to follow for common conditions

• Other topics pertinent to each licensee

The licensee and veterinarian should consider reviewing and updating the 

written program of veterinary care as needed for situations such as:

• Change in the preventive medical program

• Addition of a new species of animal

• New location or site
--- Animal Care Inspection Guide ---

Savedate 12/7/2021 9:38 AM Veterinary Care Requirements for Licensees 6-10

6.3. Records

Required Records

A licensee must maintain the required records relating to the veterinary care of 

his/her animals and medical records for dogs [3.13(b)] and marine mammals 

[3.110(d)].

Required veterinary care records must be readily available to APHIS officials for 

review [2.126(a)(2)]. 

Records can be maintained at the veterinary clinic as long as they are available to 

the inspector on request.

6.3.1.1. Dogs

6.3.1.1.1. Medical Records for Dogs [3.13(b)]

A licensee with dogs must:

• Keep copies of medical records for dogs, and

• Make the records available for APHIS inspection

Medical records for dogs must include:

• Identity of each animal including:

o Identifying marks

o Tattoos

o Tags

o Breed

o Sex 

o Age

• If a medical problem is identified (such as disease, injury, or illness), the 

following information is required in the dog’s medical record:

o Date the problem was identified

o Description of the problem

o Examination findings

o Test results

o Plan for treatment and care

o Treatment procedures performed, when appropriate 

• Names of all vaccines administered and the date(s) of administration

• Names of any treatment administered and the date(s) of administration

• Dates and findings/results of all:
--- Animal Care Inspection Guide ---

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o Screening

o Routine or other required or recommended tests

o Examinations

Medical records for dogs must be kept and maintained:

• For at least one year after the dog is euthanized or disposed of, and

• For any period in excess of 1 year as necessary to comply with Federal, State,

or local law, and

• If notified by the APHIS Administrator in writing that specified records must 

be retained pending the completion of an investigation or proceeding under 

the Act, the records must be held until their disposition is authorized by the 

Administrator 

6.3.1.1.2. Other Records for Dogs

The following records requiring veterinary approval are required for dogs and 

cats, when applicable:

• Exercise plan for dogs [3.8]

• Attending veterinarian approved exercise exemption [3.8(d)(1)]

• Health certificate for transport [2.78(a)]

6.3.1.2. Cats

The following record requiring veterinary approval is required for cats, when 

applicable:

• Health certificate for transport [2.78(a)]

6.3.1.3. Nonhuman Primates

The following records requiring veterinary approval are required for nonhuman 

primates, when applicable:

• Attending veterinarian approved EEP exemption [3.81(e)(1) and (3)]

• Health certificates signed by a licensed veterinarian for transport [2.78(a)]

6.3.1.4. Marine Mammals

The following record requiring veterinary approval is required for marine 

mammals, when applicable:

• Health certificates signed by the attending veterinarian for transport 

NOTICE

Routine husbandry (such as vaccinations, preventive medical procedures, or 

treatments) performed on all dogs in a group/herd may be kept on a single 

record.
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[3.112(a)]

Individual marine mammal medical records must be kept, and include the 

following information, at a minimum [3.110(d)]:

• Animal identification/name

• A physical description, such as:

o Identifying markings

o Scars

• Age

• Sex

• Physical examination information including, but not limited to [3.110(d)(2)]:

o All diagnostic test results

o Documentation of treatment

o Identification of all medical and physical problems

o Length

o Physical examination results by body system

o Proposed plan of action for medical/physical problems

o Weight

Individual animal medical records must be kept and available for APHIS 

inspection [3.110(d)].

A copy of the individual marine mammal’s medical/health record must 

accompany the animal if it is transferred to another facility, including contract 

and satellite facilities [3.110(e)].

6.3.1.4.1 Marine Mammal Necropsy Reports

The preliminary necropsy report must [3.110(g)(1)]:

• Be prepared by the veterinarian conducting or supervising the necropsy

• List all pathological lesions observed

The final necropsy report must include [3.110(g)(1)]:

• All gross findings

• All histopathology findings

• A pathological diagnosis

• Results of all laboratory tests performed

Necropsy reports must be [3.110(g)(2)]:

• Available for APHIS inspection

• Kept for 3 years
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• Maintained at the home facility of the marine mammal, AND

• Maintained at the facility where the marine mammal died, if different than 

the home facility

Non-Required Information

The following information is not required but may be helpful for the licensee to 

gain and maintain compliance:

• Animal observation and treatment logs which could include:

o Documentation of an acute or chronic medical issue

o Documentation of contact with the attending veterinarian

o Treatment prescribed by the attending veterinarian

o Treatment records, i.e., dates and times of treatment if applicable

o Results of treatment

• Attending veterinarian approval of noncommercial diet for large felids

• Enrichment logs for NHPs

• Feeding of young animals, such as bottle feeding

• Vaccination and preventive health records (individual animal or group/litter)

• Necropsy records (for animals other than marine mammals)

• Surgery records

• Euthanasia records

• Cage wash validation sheets

• Room maintenance logs

• Standard operating procedures, if available

Traveling Exhibitors

Traveling exhibitors should have the appropriate records with them on the road, 

as detailed in this section. See Traveling Exhibitor Inspection in Chapter 4 for 

more information.
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6.4. Inspection Guidance

General Information

All of the covered animals and the facility’s program of veterinary care and 

veterinary care practices and records should be thoroughly reviewed during the 

inspection. The information in this section is provided for your guidance but all 

citations must be based on the Regulations and Standards. If you are unsure, 

you should contact your SACS.

Adequate Veterinary Care

Sections 2.33, 2.40 and 3.13 require regulated facilities to establish and maintain 

“programs” of adequate veterinary care. The purpose in requiring a program of 

adequate veterinary care is to ensure that facilities attend to the health needs of 

animals. The program of adequate veterinary care must include having 

appropriate facilities, personnel, equipment, and services to comply with the 

Regulations; appropriate methods to prevent, control, diagnose, and treat 

diseases and injuries, including emergency and weekend care; daily observation 

of all animals to assess their health and well-being; guidance by the attending 

veterinarian to personnel in animal care and use techniques, including the use of 

pain-relieving drugs and euthanasia; and adequate pre-procedural and postprocedural care. Upon inspection, you should evaluate the appearance and 

condition of the animals as well as the facility, to determine whether the overall 

veterinary care program is adequate to ensure that proper care is being 

rendered, and whether the facility is following its written program of veterinary 

care.

An animal is considered to have received adequate veterinary care if it has been:

• Discussed with or examined and evaluated by a qualified veterinarian (either 

the attending or a consulting) in a timely manner, and

• Prescribed a treatment plan which is appropriate for the animal’s condition, 

potentially including further observation without treatment if appropriate, 

and

• Treatments have been administered as prescribed

The outcome of the treatment is not the determining factor for the adequacy of 

veterinary care, provided that the care is in keeping with appropriate standards 

of veterinary care. 

If the treatment plan provided was not adequate, appropriate, or timely, the 

inspector may contact his/her SACS for additional guidance if needed. 

6.4.2.1. Determining Adequate Veterinary Care

If there are minor veterinary issues (e.g., nails, teeth, minor injuries, and eyes) 

with little or no discernible impact on an animal’s overall health and that are 
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observed in only a small number of the facility’s animals, and the issues can be 

rapidly addressed, a facility is maintaining adequate veterinary care because, 

overall, the facility has demonstrated it has an ongoing program that provides 

adequate care to animals and is, therefore, in compliance. 

If an inspector identifies one or more animals with serious veterinary issues that 

require medical attention, or more than a small number of animals experiencing 

minor veterinary conditions (as described above), the inspector should 

determine if the facility is in compliance for adequate veterinary care.

Facility is in compliance if:

1. The veterinary care issue was identified by the facility prior to your 

inspection and the facility is authorized (for example, in the PVC or an SOP) 

to provide treatment for the condition without contacting the attending 

veterinarian, and the treatment plan is being followed, and the animal 

appears to be responsive to the treatment, or

2. The veterinary care issue was identified by the facility prior to your 

inspection, and the facility contacted the attending veterinarian (verified by 

the inspector through records, receipts and/or treatment logs or by contact 

the AV), and the treatment plan is being followed, and the animal appears to 

be responsive to the treatment, or

3. The veterinary care issue was identified by the facility prior to your 

inspection, and the facility is following the authorized treatment plan or has 

contacted the attending veterinarian, and the treatment plan is being 

followed but does not appear to be effective (i.e., the animal’s condition is 

clearly declining or worsening), and the licensee has re-contacted the 

attending veterinarian for additional instructions and is following those 

instructions (verified by the inspector through records, receipts and/or 

treatment logs, or by contacting the AV), or

4. The veterinary care issue occurred after the last daily observation on that 

day, or

5. The veterinary care issue could not have been observed by the facility and 

the facility did not have a 2.40(b)(2) or (b)(3) citation within the last 3 years

Facility is not in compliance if:

1. The veterinary care issue was not identified by the facility prior to your 

inspection, and veterinary care issue occurred prior to the daily observation 

for that day, and the facility is authorized to provide treatment, but the 

attending veterinarian’s treatment is not being followed, and you have 

contacted the attending veterinarian and the attending veterinarian is not 

comfortable with the facility’s treatment or management of the issue, or

2. The veterinary care issue was not identified by the facility prior to your 

inspection, and veterinary care issue occurred prior to the daily observation 

for that day, and the facility did contact the attending veterinarian, but the 

treatment is not being followed, and you have contacted the attending 
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veterinarian and the attending veterinarian is not comfortable with the 

facility’s treatment or management of the issue, or

3. The veterinary care issue was not identified by the facility prior to your 

inspection, and veterinary care issue occurred prior to the daily observation 

for that day, and the facility did not contact the attending veterinarian, and 

the facility had a 2.40(b)(2) or (b)(3) citation within the last 3 years, or

4. The veterinary care issue was not identified by the facility prior to your 

inspection, and the veterinary care issue occurred prior to the daily 

observation for that day, and the facility did not contact the attending 

veterinarian, and the facility did not have a 2.40(b)(2) or (b)(3) citation within 

the last 3 years, and the veterinary care issue should have been observed by 

the facility 

Guidance for Communicating with the Attending Veterinarian

If the inspector cannot determine from facility records, receipts, and/or 

treatment logs if the attending veterinarian was contacted, the next step is to 

contact the attending veterinarian. In most situations, a telephone call with the 

attending veterinarian is sufficient to confirm communication with the licensee, 

whether or not the attending veterinarian was consulted, and what if any 

instructions were given to the licensee. 

If the attending veterinarian confirms that he/she was contacted by the licensee 

about the animal, and the licensee is following the instructions, then the licensee 

is in full compliance with the provision to provide adequate veterinary care

If the attending veterinarian has not been contacted, and/or instructions are not 

being followed, cite the NCI under the appropriate paragraph in 2.40 for failure 

to provide adequate veterinary care

If the inspector needs to contact the attending veterinarian, the following 

guidance should be followed:

• The inspector should make two attempts to contact the attending 

veterinarian using the number provided by the licensee, leaving messages 

after each attempt. The first call should be made after the animals have 

been observed, and a second call should be attempted during the exit 

interview.

• If the attending veterinarian doesn’t return the calls, the inspector should ask 

the licensee for assistance with communicating with the attending 

veterinarian

• If the contact with the attending veterinarian cannot be made while on site, 

explain to the licensee that if the attending veterinarian does not respond 

within the following two business days, then an NCI will be cited under 2.40 

for failure to provide adequate veterinary care

• During the exit interview, explain that although not required, it would be 

helpful in the future for the licensee to keep a record of visits or other 
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communications with the attending veterinarian that includes the date, time, 

animal ID, and treatment and/or observation/follow up instructions

• If by the morning of the second business day the inspector has not heard 

from the attending veterinarian, notify the licensee that morning that the 

attending veterinarian has not communicated with you. And advise the 

licensee that if you don’t hear from the attending veterinarian by COB, you 

will be issuing a report with a citation.

• If an inspector believes it would be best to meet with the attending 

veterinarian in person, he/she should contact the attending veterinarian 

ahead of time, to make sure a time convenient for the attending veterinarian 

is arranged: 

o Note: if the licensee prefers, he/she should initially contact the attending 

veterinarian to help set up a call or meeting

o If an ACI does not have an established relationship with the attending 

veterinarian, it will often help to involve a VMO or SACS in the first 

meeting

• When communicating with the attending veterinarian, you must always:

o Be respectful

o Be professional

o Be cognizant of his/her time

o Inform him/her of Attending Veterinarian module on our website

o Provide our AV-related tech notes and extension pamphlets (as available)

o Thank them for their time

• When communicating with the attending veterinarian:

o Introduce yourself and that you are conducting an inspection of the USDA 

licensed/registered facility, and provide the name of the licensee

o Explain that the purpose of the call is to simply confirm whether or not 

they have examined and/or communicated instructions for the veterinary 

medical condition of the specific animal of concern. Provide the species, 

breed, color, age, gender, ID number, and location of the animal.

o Conclude the conversation by thanking them for their time, and offer 

your phone number in case they would like to contact you in the future 

for any reason

o Do not challenge the attending veterinarian’s diagnosis or instructions

o If the attending veterinarian states that communication or treatment 

took place, we accept that fact

o We do not pay consulting fees for attending veterinarians (should that 

come up in conversation)
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• If you have not had the opportunity to meet with the attending veterinarian 

at a facility, consider reaching out to introduce yourself and see if they have 

any questions about attending veterinarian responsibilities under the AWA 

proactively, before the need arises. Building a relationship and open line of 

communication with attending veterinarians will help ensure animal welfare 

and facilitate discussions regarding specific animals and treatments in the 

future as needed.

Recognition of Pain and/or Distress

It is often difficult to assess pain and/or distress in animals because of a lack of 

methods to validate and objectively measure the pain or distress. Additionally, 

not all animals demonstrate pain or stress in a similar manner. Basic biology, 

natural history, and individual variation all have a significant impact on the 

demonstration of clinical signs associated with pain. Listed in Table 6-1 are some 

possible signs of pain or distress.

However, presence of these signs does not necessarily mean the animal is in pain 

or distress. Or a lack of these signs also does not mean that the animal is not in 

pain or distress. If you see conditions that are likely painful and animals are not 

showing clear signs, or if you are seeing signs that are suggestive of pain/distress 

and are unsure of why, you should contact your SACS or the appropriate Species 

Specialist for help with interpreting the situation.

Table 6-1. Signs of Pain and/or Distress

Species Species-Typical Signs of Pain

Dogs Quiet, reluctant or unwilling to move, abnormal posture, 

lameness, lack of alertness, whimpering, groaning, howling, 

shivering, loss of appetite, increased respiration, growl or 

exhibit apprehension when approached, looking at, licking at, 

rubbing, or chewing a wound or potentially painful area, 

response elicited when touching or manipulating an area 

(withdrawal, whine, snap, etc.)

Cats Ungroomed/unkempt appearance, greasy hair coat, 

quiet/withdrawn, apprehensive facial expression, loss of 

appetite, crying, hissing, hiding (often in litter box), crouching, 

or hunching, purring, tail flicking, response to handling (often 

aggressive but individuals may also purr in combination with 

other signs)

Guinea Pigs Quiet, lethargy, decreased activity, decreased food and water 

consumption, anorexia, rough hair coat, reluctance to move, 

sunken eyes

Hamsters and 

Gerbils

Decreased activity, piloerection, ungroomed appearance
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Species Species-Typical Signs of Pain

Rabbits Inactivity, appear apprehensive or anxious, hunched 

appearance, hide, squeal or cry, possible aggressive behavior 

with excessive scratching and licking, facial expression 

(tightening of eye, cheek flattening, nostril tightening, pulling 

back whiskers, tightening ears)

Nonhuman 

Primates

May mask signs of pain, appearance of misery and/or 

dejection, huddling or crouching, stops eating/drinking, sad 

expression, moaning, screaming, stops grooming, clenching of 

teeth, self-directed injuries, licking / chewing at injury, 

impaired used of limb, guarding behavior, dilated pupils

Marine 

Mammals 

Cetaceans: 

dolphins, 

porpoises, and 

whales

Tend to mask illness/pain, arching/hunching, squinting, one or 

both eyes closed, regurgitation, inappetence, changes in 

behavior, unusual posture in pool, floating at surface or 

sinking to the bottom, reduced activity, animal isolating itself 

from others in pool, dull or excessive sloughing of skin

Marine 

Mammals 

Pinnipeds: 

Seals, Sea Lions, 

Walrus

Typically stoic, laying with flippers tucked to sides, decreased 

activity, reduced alert behavior, rubbing / biting affected 

areas, blinking, squinting / one or both eyes closed, decreased 

time in pool, social isolation, decreased appetite, excessive 

vocalization (especially walrus)

Bears Typically stoic, may show decreased foraging / appetite, 

decreased locomotion, slow / reluctant to move, 

development of stereotypic behaviors

Big Cats Typically stoic, may show slow / weak / abnormal gait, 

obvious lameness, reluctance to rise / ambulate, hair pulling, 

chewing / biting, quite depressed attitude / lethargic, eyes 

frequently squinting or closed. Note: young cubs that are 

excessively handled may be too weak, cold, or exhausted to 

show overt signs of distress or pain.

Elephants Often subtle and hard to detect. Lameness, shifting weight, 

“bucket stance”, localized heat / swelling, reluctance or slow 

response to per- form trained behaviors, movement away 

from touch (by trainers), head pressing, trunk pressing, 

restlessness / touching abdomen / kicking abdomen (similar 

to colic in a horse), excessive blinking (eye pain), changes in 

ear flapping frequency, decreased appetite (though chewing 

hay may also be a soothing behavior)

Cattle Dull, depressed appearance, heads bowed, lack of alertness, 

loss of appetite, rapid/shallow breathing, rigid posture
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Species Species-Typical Signs of Pain

Pigs Changes in overall demeanor, social behavior, gait, and 

posture, unwilling to move, hiding, excessive squealing when 

handled

Sheep and 

Goats

Similar to cattle and vocalization, teeth grinding, increased lip 

curling, isolation from the flock

Exotic Hoof 

stock

Similar to other ruminants, although individuals may be more 

adapted to hiding overt signs of pain, lameness, gait 

abnormalities, misshapen hooves (with long-term weight 

bearing abnormality)

6.4.4.1. Signs of Distress

Possible signs of distress in an animal include, but are not limited to:

• Change in the animal's behavior

• Abnormal behavior, such as stereotypies

• Abnormal respiration (shallow, rapid, panting, etc.)

• Reduced grooming

• Runny, glassy, or unfocused eyes

• Hunching or cowering in a corner of the cage

• Changes in body weight

• Absence of alertness or inattention to ongoing stimuli

• Vomiting

• Decrease in appetite and water intake

• Intense or frequent vocalizations

• Hair plucking and self-trauma

• Young animals dispersing from nests/dens (such as seen with heat stress)

It is important to remember that signs of distress such as the presence of 

stereotypic behaviors may outlast the cause for the development of those 

behaviors. If you observe abnormal behavior such as stereotypic behavior it is 

important to discuss the behavior with the facility to determine when the 

behavior began and what is being done (if anything) to address the behavior. If 

you are unsure if an animal is exhibiting signs of either pain or distress, or 

whether the facility's response is adequate you should discuss with your SACS.

Medication and Medical Supplies

The inspector must ensure that all medications and medical supplies at licensed 
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facilities are being used in a manner that is consistent with providing adequate 

veterinary care to prevent, control, diagnose and treat disease and injuries. 

[2.40(b)]

Methods to assess the use of medications and medical supplies to provide 

adequate veterinary care include, but are not limited to: 

• The licensee has directions for appropriate use of all medications and 

medical supplies prescribed by a licensed veterinarian. The licensee should 

be able to demonstrate knowledge of the:

o Name and concentration of the medication and appropriate use, dose, 

frequency, and route of administration

o Instructions for use of the medication which may be located on a 

prescription label directly on the product or documented in writing from 

a veterinarian, as long as the information is readily accessible, 

understandable, and available for use at the facility

• All medications and medical supplies are:

o Stored within manufacturers recommended humidity and temperature 

range

o Protected from light (if required)

o Labeled appropriately, including the drug name, concentration, and 

expiration date if transferred out of the original container

o Stored in a manner that prevents contamination

• Expired medications or medical supplies are NOT being used for covered 

animals

• If expired medications or medical supplies are present at the facility, to avoid 

misuse the inspector may recommend that they be:

o Clearly labeled “expired”

o Separated from other medications and medical supplies

6.4.5.1. Medications of Special Welfare Concern

The licensee must establish and maintain programs of adequate veterinary care 

that include:

• Adequate guidance to personnel involved in the care and use of animals 

regarding handling, immobilization, anesthesia, analgesia, tranquilization,

and euthanasia [2.40(b)(4)]

Certain medications used for these procedures present special animal welfare 

concerns, particularly when used by non-veterinarians without the direct 

supervision of a veterinarian. Listed below are some methods to assess the 

proper use medications for these purposes.
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6.4.5.1.1 Paralytics or Neuromuscular Blocking Drugs

The use of paralytic or neuromuscular-blocking drugs without direct veterinary 

administration, oversight, and care (including the use of general anesthesia and 

respiratory support) is not consistent with providing adequate veterinary care 

[2.40(b)(2), 2.40(b)(4)].

6.4.5.1.2 Anesthetics and Controlled Drugs

The use of anesthetics, including certain controlled drugs, by non-veterinarians 

without the direct supervision of a veterinarian, may not be consistent with 

providing adequate veterinary care.

If you identify anesthetics during an inspection, you should visit with the licensee 

and review available records of use and determine how the facility uses the 

drugs, including but not limited to:

• Species

• Purpose

• Administration practices, including dosing, route of administration, and 

names/doses of any drugs given with it

• Monitoring practices during and after administration

• Supportive care provided

• Procedures or handling occurring after administration

• Training and qualifications of individuals giving the drug(s)

Anesthetics, including certain controlled drugs, should:

• Be used in accordance with any local, State, or federal laws

• Be used according to the written instructions for use by the veterinarian, 

including dose, frequency, and route of administration

• Only be used by personnel with appropriate training to ensure the 

anesthetics are used in a method that is consistent with providing 

appropriate veterinary care (see below)

• Be stored within manufacturers recommended humidity and temperature 

range and protected from light (if required)

• Be stored in a manner that prevents contamination

If the individual(s) administering the anesthetics is not a veterinarian or is not 

directly supervised by a veterinarian, then you should assess the training and 

qualifications of the individual by inquiring about his/her ability to:

• Monitor vital signs such as respiration, heart rate, and hydration status

• Recognize the effects of the drug, including signs of overdose or underdose

• Recognize when medical intervention is necessary and what steps to take
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Surgeries and Specialized Surgical Procedures

The licensee must establish and maintain programs of adequate veterinary care 

that include, but are not limited to:

• The availability of appropriate facilities, personnel, equipment, and services 

to comply with the Regulations and Standards

• The use of appropriate methods to prevent, control, diagnose, and treat 

diseases and injuries

• Adequate guidance to personnel involved in the care and use of animals 

regarding handling, immobilization, anesthesia, analgesia, tranquilization, 

and euthanasia

• Adequate pre-procedural and post-procedural care in accordance with 

established veterinary medical and nursing procedure [2.40(b)(5)] 

If surgeries and/or specialized surgical procedures are being performed at a 

licensed facility, the inspector should ensure that:

• The attending veterinarian has been consulted by the licensee

• The licensee is following all of the attending veterinarian's guidance

• All animals are receiving adequate veterinary care

• All procedures are being conducting consistent with standard veterinary 

practice

The inspector should evaluate the qualifications and assess the adequacy of 

training of non-veterinarians conducting surgeries. Sample questions that you 

could ask the personnel about the procedures they are performing include but 

are not limited to:

• What are the signs of pain and distress and related questions, such as:

o Describe the drug regimen that will be used

o Describe anticipated effect of the drug

o Describe the signs of pain relief

o Describe when further intervention may be necessary

o What is the plan if the pain is not relieved

o When will the veterinarian be called

• Describe the aseptic technique used, including use of gloves, masks, tools, 

and steps taken to appropriate clean the area and equipment between 

animals

• Describe the steps of the procedure to ensure they are following guidance 

from the attending veterinarian and verify appropriate veterinary care

• Which vital signs are being monitored and related questions such as:

o Describe the operation of the monitoring equipment
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o Describe the interpretation of the results of the monitoring

• Describe the length and interval of monitoring and when it will be 

discontinued

• Describe ability to recognize and respond to potential veterinary medical 

emergencies that could occur, including excessive bleeding, cessation of 

breathing, or other potential complications and related questions, such as:

o When is medical intervention necessary

o What medical intervention will be used

o What equipment available for medical intervention and how is it 

operated

o When will the veterinarian be called

Euthanasia Guidance for Inspections

The Animal Welfare Act Regulations (AWAR) define “euthanasia” (9 C.F.R. § 1.1) 

as:

• The humane destruction of an animal accomplished by a method that 

produces rapid unconsciousness and subsequent death without evidence of 

pain or distress, OR

• A method that utilizes anesthesia produced by an agent that causes painless 

loss of consciousness and subsequent death

This is the regulatory standard inspectors must apply when determining whether 

a method of euthanasia is compliant with the AWA. Facilities, in consultation 

with their attending veterinarian, may determine the humane method of 

euthanasia they wish to use provided it meets the regulatory standard.

AVMA Guidelines on Euthanasia

• The methods of euthanasia listed as “Acceptable” or “Acceptable with 

Conditions” (when conditions are met) in the American Veterinary Medical 

Association’s (AVMA) Guidelines on Euthanasia meet the regulatory 

definition of euthanasia, and facilities may consider the AVMA guidelines as a 

source that describes humane methods of euthanasia that are compliant. 

• The AVMA Guidelines themselves cannot be enforced because they are not 

part of the Regulations. This means an inspector cannot cite a facility for the 

failure to provide adequate veterinary care because the facility’s method of 

euthanasia is not listed as an “acceptable” or “conditionally acceptable” 

(with conditions met) method of euthanasia in the AVMA Guidelines. 

Instead, the inspector must assess whether the facility’s method of 

euthanasia meets the regulatory definition above, and, if not, explain in the 

citation how the method does not meet the definition. 
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6.4.7.1. Methods of Euthanasia Listed as “Acceptable with Conditions” in the 

AVMA Guidelines

If the method of euthanasia is “acceptable with conditions,” the inspector must 

confirm the facility is following the specified conditions by:

• Reviewing the program of veterinary care (PVC), and

• Asking the licensee/registrant questions and/or visiting with the attending 

veterinarian (AV)

6.4.7.2. Methods of Euthanasia Not Listed as Acceptable or Acceptable with 

Conditions in AVMA Guidelines

To assess whether a method meets the regulatory definition, the inspector must 

discuss the method with the licensee and the attending veterinarian and review:

• The method of euthanasia the attending veterinarian approved for use at the 

facility

• How the method of euthanasia is administered

• The factors the licensee and attending veterinarian considered when 

adopting the method

• What equipment is required to carry out the method

• The observation of the animal and its behavior/appearance before, during, 

and after applying the method

• How the animal’s death is confirmed

• The timeframe between administering the method and the animal’s death

• Any other questions the inspector thinks are relevant to assessing 

compliance with the regulatory standard

6.4.7.3. Method of Euthanasia Not on the PVC or as Described by the AV

If the facility is using a method of euthanasia that is not the same method listed 

in the PVC or described by the attending veterinarian, and the facility is 

performing the euthanasia, the inspector should include a citation on the 

Inspection Report under 2.40(b)(4) for using a method of euthanasia not 

consistent with the attending veterinarian's guidance. 

6.4.7.4. Facility Conducting Euthanasia

If a facility is conducting euthanasia, the inspector should determine whether: 

1. The person the attending veterinarian approved to perform the specific 

method of euthanasia is performing the euthanasia, and

2. The attending veterinarian provided the person(s) with adequate training 

and guidance for properly conducting the euthanasia, and
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3. The facility maintains appropriate facilities, equipment and/or supplies

4. If any of these conditions are not met, the inspector should include a citation 

on the Inspection Report under 2.40(b)(4) for lack of adequate guidance 

and/or 2.40(b)(1) for lack of appropriate facilities, equipment, or supplies

6.4.7.5. Other Important Notes

• Euthanasia conducted under emergency conditions may require extreme 

measures, and inspectors who encounter situations like this should discuss 

them with their SACS

• Assessing compliance involves applying the regulatory definition of 

euthanasia. Any noncompliance involving euthanasia should describe why 

the method does not meet the regulatory definition. A method of 

euthanasia not found in the AVMA Guidelines is not necessarily a 

noncompliance with the Regulations. Citations in Inspection Reports and 

justifications in inspection appeals must focus on the regulatory definition of 

euthanasia and must not rely upon (or reference) the AVMA Guidelines.

• If needed, the SACS and inspector can request guidance from the AWO on 

whether the method meets or does not meet the regulatory definition of 

euthanasia. If the AWO determines the method of euthanasia does not meet 

the regulatory definition, AWO will issue a written correspondence to the 

facility to convey the determination to the facility and the attending 

veterinarian, and will list available resources pertaining to the humane 

euthanasia of animals (including the AVMA Guidelines, the Canadian Council 

on Animal Care Guidelines on: Euthanasia of Animals Used in Science (which 

can be found at 

http://www.ccac.ca/Documents/Standards/Guidelines/Euthanasia.pdf), and 

guidelines in the European Food Safety Authority Journal, pp 25-42 (which 

can be found at 

http://onlinelibrary.wiley.com/doi/10.2903/j.efsa.2005.292/epdf)

Additional Requirements for Inspecting Dogs

For all Routine Inspections, you, the inspector, should:

• Examine dogs according to the following criteria:

o Ask the licensee to pull from the enclosure any dog showing signs of a 

medical issue if you need have a closer look and take photos and/or a 

video to document any veterinary care noncompliance, and

o Ask the licensee to pull any dogs that were previously identified as having 

a medical issue to recheck the dog if you need a closer look, and

o Select 10 percent of the remaining dogs (up to maximum of 10 dogs) for 

the licensee to pull and check for medical issues associated with their 

mouths, ears, eyes, skin, general condition, etc.
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• Inspect the entire dog for medical issues; do not just focus on a single specific 

area

• Check for proper identification

For all Prelicense Inspections, you, the inspector, should:

• Examine dogs according to the following criteria:

o Ask the applicant to pull from the enclosure any dog showing signs of a 

medical issue if you need to have a closer look, and

o Ask the applicant to pull any dogs that were previously identified as 

having a medical issue to recheck the dog if you need a closer look, and

o Select 10 percent of the remaining dogs (up to maximum of 10 dogs) for 

the applicant to pull and check for medical issues associated with their 

mouths, ears, eyes, skin, general condition, etc. If you identify a 

veterinary care issue that would normally be cited during a Routine 

Inspection, then it must be cited on the Inspection Report for the 

Prelicense Inspection.

• Inspect the entire dog for medical issues; do not just focus on a single specific 

area

NOTICE

Remember to use proper biosecurity measures.
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6.5. Documentation of Veterinary Care NCIs

Citing Section 2.40(b)(2) or 2.40(b)(3)

6.5.1.1. Section 2.40(b)(2)

Section 2.40(b)(2) is cited whenever a sick or injured animal:

• Has not been evaluated by the veterinarian either via a physical examination 

or consultation, or

• Lacks a post-treatment re-evaluation if the veterinary care issue is not 

resolved, or

• Is not being treated according to the treatment plan in the written program 

of veterinary care or as instructed by a veterinarian

Correction of this NCI usually involves a consult or examination by a veterinarian, 

whichever is more appropriate.

6.5.1.2. Section 2.40(b)(3)

Section 2.40(b)(3) is cited when the facility has a problem where sick or injured 

animals are not receiving appropriate veterinary care due to:

• Inadequate or no daily observation to identify sick/injured animals, and/or

• Lack of timely communication with the veterinarian on issues of animal 

health

Correction of this NCI involves either adequate daily observation and/or timely 

communication with the veterinarian about issues of animal health.

NOTICE

Section 2.40(b)(2) and (b)(3) should not both be cited for the same animal(s). 

The inspector should cite the most appropriate Regulation. However, if the 

inspector finds a situation where they believe it is appropriate to cite both 

Regulations, this should be discussed with the SACS.
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Research Facility Inspection

Contents

7.1. IACUC Review Information 7-3

General Information 7-3

Review of the Program of Humane Care and Use and Facility 

Inspection 7-5

Reports to the Institutional Official 7-6

Protocol Activity Suspension 7-7

Complaints or Concerns 7-8

Records 7-8

Significant Changes to Animal Activities 7-8

Telecommunications for IACUC Meetings 7-9

Information to Review 7-10

7.2. Protocol Review Information 7-12

Inspection Protocol Review Guidance 7-12

Protocol Approval Process 7-14

Protocol Review 7-14

Specific Types of Protocols 7-17

Inspection Procedures 7-21

7.3. Veterinary Care Requirements for Dogs 7-24

7.4. Contracted Research or Projects that Involve Multiple Registrants 7-27

No Delegation of Responsibilities 7-27

Specific Responsibilities 7-27

All Responsibilities Designated 7-28

7.5. Records 7-29

Required Research Facility Records 7-29

Animal Records 7-29

Annual Report 7-30

Retention 7-34

Availability 7-34

Confidentiality and Removal of Records 7-34

7.6. Guidance for Veterinary Schools and Veterinary Technician Programs 

(VTP) for the Inspector 7-36

Teaching versus Research 7-36

Inspection Procedures 7-36

Special Considerations 7-37

7.7. Inactive Research Facility or Research Facility with No Activity for 

Two Years Inspection 7-38

Inactive Research Facility 7-38

Research Facilities with No Regulated Activity for Two Years 7-38

7.8. Holding Period 7-40
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7.9. Research Facility Protocol Selection Worksheet 7-41

DISCLAIMER

The Animal Welfare Inspection Guide is intended to be a reference document to assist the 

inspector. The Inspection Guide does not supersede the Animal Welfare Act (AWA), the AWA 

Regulations and Standards, AC policies and other guidance, the Required Inspection 

Procedures, standard procedures, or the inspector’s professional judgment. All inspection 

decisions must be justified by applicable sections of the AWA and/or the AWA Regulations 

and Standards.
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7.1. IACUC Review Information 

General Information

All IACUC responsibilities, functions, and activities must be completely and 

thoroughly reviewed.

7.1.1.1. Criteria

The IACUC must be qualified through the experience and expertise of its 

members to assess the research facility’s [2.31(a)]:

• Animal program

• Facilities

• Procedures

Except as specifically authorized by law or the Animal Welfare Act Regulations, 

the Animal Welfare Act and its Regulations do not authorize a research facility’s 

IACUC to dictate to a researcher how to conduct his/her research by [2.31(a)]:

• Prescribing methods for the design or performance of research or 

experimentation

• Setting standards for the design or performance of research or 

experimentation

7.1.1.2. Membership

The Chief Executive Officer (CEO) of the research facility must appoint an 

Institutional Animal Care and Use Committee (IACUC) [2.31]. If the CEO 

delegates authority to appoint the IACUC, the delegation must be specific and in 

writing. (Note: This requirement is consistent with OLAW Policy)

The IACUC must be composed of [2.31(b)(2) and (3)]:

• A Chairperson

• At least one Doctor of Veterinary Medicine (DVM)

• At least one nonaffiliated member

Although not specifically prohibited by the AWA, APHIS strongly discourages one 

person from filling more than one of those positions. 

NOTICE

The AWA specifically prohibits Animal Care from stopping research at any 

research facility (registered or unregistered but requiring registration).

Therefore, you (the inspector) may NOT instruct a research facility to stop 

conducting research under any circumstances. [AWA 2143(a)(6)(A)]
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In assessing IACUC membership, you should evaluate whether:

• All the required positions are filled

• The DVM has training or experience in laboratory animal science and 

medicine, who has direct or delegated responsibility for activities involving 

animals at the research facility

• The nonaffiliated member represents the general public, i.e., has no conflict 

of interest either personally or financially, and is not a laboratory animal user 

at any research facility

• There are no more than three members from one administrative unit of the 

research facility, unless the facility only has one administrative unit

• IACUC members are qualified to assess the research facility’s animal 

program, facilities, and procedures

7.1.1.3. Alternate Members

There may be alternate members appointed to the IACUC by the Institutional 

Official (IO).

Alternates may only serve as an alternate in the membership category(s) for 

which they are qualified. For example, the alternate for a non-affiliated IACUC 

member would need to also meet the non-affiliated member requirements.

If the regular member fulfills a specific membership requirement(s), his or her 

alternate must also fulfill that requirement(s). 

One alternate may be appointed to serve for multiple regular members provided 

the alternate fulfills the specific membership requirement of the members for 

whom he or she is substituting. However, an alternate may not represent more 

than one member at any one time.

Note: This guidance is consistent with the OLAW Policy.

7.1.1.4. IACUC Meetings

In assessing IACUC meetings, you should evaluate whether:

• All members are informed of all meetings

• Meetings are held at a time when all members, especially the nonaffiliated 

member, can attend

• Required members (committee chair, nonaffiliated member, and attending 

veterinarian) are in attendance at most meetings. (There is no requirement 

NOTICE

If a required position(s) is unfilled, there is not a properly constituted IACUC. 

An improperly constituted IACUC cannot perform the required official AWA 

functions.
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that all required members must be in attendance at all meetings.)

•

• All members have access to information distributed, e.g., if sent only over 

email, all members must have email

• All members are sent information for an IACUC meeting in sufficient time 

prior to the meeting to be able to review the information

• All members receive a list of protocols, or the actual protocols to be 

reviewed, in sufficient time to participate in the review or request a full 

committee review

• There is a mechanism for a member to request a full IACUC review of a 

protocol or participation in the appointed subcommittee review

• If a member requests a full IACUC review of a protocol, a full IACUC review is 

conducted

7.1.1.5. Minutes

The IACUC meeting minutes should include:

• A record of attendance

• All the activities conducted by the IACUC at the meeting

• Committee deliberations including the decisionsreached

•

Review of the Program of Humane Care and Use and Facility 

Inspection

The IACUC is responsible for determining the best method for conducting the 

review of the humane care and use program and conducting the facility 

inspection [2.31(c)(3)].

Live video feed can be used for the semi-annual inspection with the following 

provisions:

• The video feed must be live, so that IACUC members watching the video feed 

can direct the camera to focus on specific areas

• If a live video feed is used for the entire inspection, at least 2 Committee 

members must be involved with either filming or reviewing the live video 

NOTICE

If any required member is absent from a substantial number of meetings, the 

research facility may need to find a different person to fill the position.

NOTICE

For requirements for conducting meetings using telecommunications, see 

Telecommunications for IACUC Meetings.
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feed.

• No Committee member wishing to participate can be excluded

In assessing the program review, you should evaluate whether:

• The program review and facility inspection are being conducted at least once 

every 6 months

•

• If the IACUC adopted the AAALAC International Program Assessment report 

as its semiannual program review or facility inspection, the following 

requirements weremet:

o The report complied with sections 2.31(c)(1) and 2.31(c)(2) and 2.31(c)(3)

o At least two members of the IACUC assisted in conducting the inspection

o No IACUC member wishing to participate in any evaluation was excluded

o The report was signed by a majority of the IACUC members (individual 

digital signatures are acceptable)

• All members are informed of the program review to be conducted by the 

appointed subcommittee in sufficient time to request participation

• No IACUC member wishing to participate in the review is excluded

• The program of humane care and use and facility inspection address all of 

the required areas

• Any identified departure from the AWA Regulations and Standards includes a 

description of and reason for the departure

Reports to the Institutional Official

In assessing the reports to the IO, you should evaluate whether:

• A report(s) is submitted at least every 6 months, after each program review 

and facility inspection

• There is a description of how and to what extent the research facility meets 

the AWA Regulations and Standards, such as:

o Facility is in total compliance and description, or

o Describes each item not in compliance (deficiency)

• Any identified departure from the AWA Regulations and Standards includes a

NOTICE

The USDA is in agreement with OLAW that the timing of the program review 

can include flexibility of within 30 days of the 6-month interval from the last 

review, as long as there is not forward drift of the date from year to year. To 

avoid forward drift, the IACUC should consider scheduling program reviews 

during the same calendar month from year to year.
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description and reason for the departure

• If a departure occurred due to a program or facility deficiency, then there is

a:

o Classification of the deficiency as a significant deficiency or a minor 

deficiency

o Description of a reasonable and specific plan for correcting the deficiency

o Schedule with dates for correcting the deficiency

• The report is signed by a majority of the members (individual digital 

signatures are acceptable)

• The report contains any minority views

Other reports that should be sent to the IO include:

• Notice of suspension of a protocol

• Uncorrected significant deficiencies

You should review how the reports are sent to the IO.

Protocol Activity Suspension

In assessing the IACUC’s suspension of protocol activities, you should evaluate 

whether:

• The activity was reviewed and suspended at a convened meeting with a 

quorum of the IACUC present

•

• The suspension was approved by majority vote of the quorum present

• The IO, in conjunction with the IACUC:

o Reviewed the reason for the suspension

o Took appropriate corrective action

NOTICE

A significant deficiency is one which is, or may be, a threat to the health 

or safety of the animal.

NOTICE

If you have a concern that the Institutional Official is not receiving the 

required reports/information or acting on the required reports/information, 

you should visit with the IO.

NOTICE

A quorum means a majority of the Committee members.
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o Informed the appropriate Animal Welfare Operations Office ofthe 

suspension, including a full explanation

o Informed other appropriate Federal funding agencies of the suspension

Complaints or Concerns

In assessing the IACUC’s responsibility for addressing complaints or concerns, 

you should evaluate whether [2.31(c)(4)]:

• The IACUC has a method for reviewing and, if warranted, investigating 

concerns involving the care and use of animals at the research facility 

resulting from:

o Public complaints 

o Reports of noncompliance received from laboratory or research facility 

personnel or employees

Records

In addition to the reports listed above, the following IACUC records must be 

available for review and in compliance with the AWA Regulations: [2.35(a)(2); 

2.35(f)]

• Protocols

• Proposed significant changes to protocols

• IACUC approval or non-approval of protocols or proposed significant changes 

to protocols

Significant Changes to Animal Activities

In support of the use of performance standards and professional judgment and 

to reduce regulatory burden, IACUC-reviewed and -approved policies (e.g., 

guidance documents, standard operating procedures, drug formularies) for the 

conduct of animal activities may be used for the administrative handling of some 

significant changes as outlined below.

The following significant changes must be approved by either full Committee 

review or designated member review:

• From nonsurvival to survival surgery

• Resulting in greater pain, distress, or degree of invasiveness

• In housing and or use of animals in a location that is not part of the animal 

program overseen by the IACUC

• In species

• In study objectives

• In Principal Investigator (PI)
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The following significant changes may be handled administratively according to 

IACUC-reviewed and -approved policies in consultation with a veterinarian 

authorized by the IACUC:

• Anesthesia, analgesia, sedation, or experimentalsubstances

• Euthanasia to any method approved in the AVMA Guidelines for the 

Euthanasia of Animals

• Duration, frequency, type, or number of procedures performed on an animal

The following significant change that may be handled administratively according 

to an existing IACUC-reviewed and -approved policy without additional 

consultation or notification is:

• An increase in previously approved animal numbers

The following changes may be handled administratively without IACUCapproved policies, consultations, or notifications:

• Correction of typographical errors

• Correction of grammar

• Contact information updates

• Change in personnel, other than the PI. (There must be an administrative 

review to ensure that all such personnel are appropriately identified, 

adequately trained and qualified and meet other criteria as required by the

IACUC.)

• Investigators may use fewer animals than approved. This does not require 

IACUC approval, notification, consultation, or administrative handling

Note: This guidance is consistent with the OLAW Policy.

Telecommunications for IACUC Meetings

Methods of telecommunications (e.g., telephone or video conferencing) are 

acceptable for the conduct of official IACUC business requiring a quorum, 

provided the following criteria are met:

• All members are given notice of the meeting

• Documents normally provided to members during a physically convened

meeting are provided to all members in advance of the meeting

• All members have access to the documents and the technology necessary to 

fully participate

• A quorum of Committee members is convened when required

• The communication system allows for real time verbal interaction equivalent 

to that occurring in a physically convened meeting (i.e., members can 

actively and equally participate and there is simultaneous communication)

• If a vote is called for, the vote occurs during the meeting and is taken in a 
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manner that ensures an accurate count of the vote. A mail ballot or 

individual telephone polling cannot substitute for a convened meeting.

• Opinions of absent members that are transmitted by mail, telephone, fax, or 

email may be considered by the convening IACUC members, but may not be 

counted as votes or considered as part of the quorum

• Written minutes of the meeting are maintained as required

All activities conducted via electronic communication must be documented in 

writing and original or electronic signatures obtained, when required.

Examples of electronic communication systems include, but are not limited to:

• Audio-visual conferencing, including webinar-based forums

• Conference calls

Fax, email, and one-on-one communication via telephone are not acceptable 

methods for conducting IACUC functions that require a convened meeting, such 

as:

• Full committee review

• Suspension of an approved activity

The use of email or one-on-one communication via telephone for these activities 

is not considered to constitute a meeting. 

Information to Review

The information below represents supplemental information and materials that 

the facility can provide that may help the inspector verify or assess IACUC 

function but are not required by the AWR.

Documents that may be reviewed to assess IACUC function may include, but are 

not limited to:

• Audio tapes provided by the research facility

• Cage wash water temperature certification records

• Emails and email records

• IACUC facility Inspection Reports

• IACUC-related correspondence

• Interviews with IACUC members

• Maintenance records

• Medical/surgical records

• Memos and notes

• Program of humane care and use

• Room temperature logs
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• Standard operating procedures
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7.2. Protocol Review Information

Inspection Protocol Review Guidance

Protocols and the IACUC approval and monitoring of protocols should be 

completely and thoroughly reviewed during an inspection.

7.2.1.1. Sampling Guidance

The inspector is responsible for conducting a thorough review of:

• The protocol approval process

• The IACUC’s monitoring of protocol activity

• IACUC-approved protocols and changes to protocols

Detailed below is guidance to assist you in evaluating the IACUC protocol review. 

However, you must use the Regulations and your professional judgment to 

determine if an IACUC or protocol is in compliance.

7.2.1.2. Prepare

• Write down the necessary ID information for any animals about which you 

havea concern, and

• Review the most recent Annual Report to identify species and numbers of 

animals used in columns E and D and all protocols with reported exceptions

• Determine whether you know of and have access to all protocols subject to 

AWA Regulations, including but not limited to:

o Active protocols

o Inactive protocols from the past 1 year, and

o Protocols where no regulated species are currently present at the facility

NOTICE

For large facilities, if you think that following these requirements will result in 

the expenditure of an inordinate amount of time, seek guidance from your 

SACS before the inspection.

NOTICE

If a protocol has been reviewed by an AC VMO within the last year, then the 

protocol does not need to be re-reviewed unless the VMO noticed a concern 

with an animal being used for that protocol.
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7.2.1.3. Review

Always review the following protocols:

• All protocols of concern identified during the inspection

• All column E protocols (if not reviewed during the last year)

• All protocols with IACUC-approved exemptions/exceptions (if not reviewed 

during the last year)

• Protocols cited as noncompliant during the last inspection

7.2.1.4. Review Additionally

• If the facility has five or fewer remaining protocols, review all remaining 

protocols

• If the facility has greater than five remaining protocols, select five additional 

protocols, including at least one protocol from each of the following 

categories, if applicable:

o Select one protocol for each regulated species present

o For the following high-risk procedures, select one from each of the 

categories below, if applicable:

- Potentially painful/distressful procedures (Column D)

- Antibody production

- Food/water restriction

- Neuromuscular blockers

- Surgical procedures

- Teaching or trauma training protocols

- Toxicity studies

- Infectious disease studies

- Vaccine potency/efficacy studies

7.2.1.5. Research Facility Protocol Selection Worksheet

You must complete the Protocol Selection Worksheet for every inspection, even 

NOTICE

You have already reviewed the protocols of concern, so this step is meant to 

ensure a ‘random’ sample of other protocols. There may be protocols in each 

of these categories at a particular facility totaling more than 5. Use your 

professional judgment to select 5 from the other species and the high-risk 

procedures categories and do your best to mix those up in subsequent years.
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if no protocols are reviewed. See Research Facility Protocol Selection 

Worksheet.

Instructions for completing the Protocol Selection Worksheet are as follows:

• Complete the section on Routine or Focused Inspection

• A protocol should only be counted once, even if it falls into more than one 

selection criteria

• All Column E protocols should be counted in the Column E row (Row #2) 

even if they also fit into another selection criteria

• For all other protocols, use your professional judgment for deciding which 

selection criteria is most appropriate for a protocol to be counted in

• Total Protocols Selected and Reviewed should equal the sum of Rows 1- 5 

After completing the Research Facility Protocol Selection Worksheet, you should:

• Scan the Worksheet into eFile with the Inspection Report

• Leave a copy with the research facility, if requested by the facility

Protocol Approval Process

The inspector should conduct a thorough review of the IACUC’sprotocol 

approval process to ensure that the IACUC is following the Regulations. 

7.2.2.1. Evaluation of IACUC Activities

Ways to evaluate IACUC activities include, but are not limited to:

• Audio meeting minutes

• Compliance Office/Officer activities if the facility has a Compliance Office

• Correspondence

• Email correspondence and email records

• Interviews with IACUC members

• Memos/notes

• Protocols

• Protocol submission forms

• Written meeting minutes

Protocol Review

7.2.3.1. General Protocol Requirements

A protocol to conduct an activity involving animals must contain and comply with 

the requirements/assurances detailed below. 
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Protocols must meet the following requirements:

• Identify the species of animals to be used [2.31(e)(1)]

• Provide the approximate number of animals to be used [2.31(e)(1)]

• Provide the rationale for using animals[2.31(e)(2)]

• Provide a rationale for the appropriateness of the species[2.31(e)(2)]

• Provide a rationale for the number of animals to be used [2.31(e)(2)]. 

Examples of rationale that may be used include, but is not limited to:

o Required for statistically significant results (tests used, or statisticians 

consulted should be included)

o Based on scientific literature or past experience 

o Based on results of pilot study

o Required by the Food and Drug Administration (FDA) or other Federal 

agency (Federal code, Regulation, or Standard, etc., should be cited)

o Required by international testing requirements (code, Regulation, 

Standards, etc., should be cited)

o Number of students/animal and procedures needed to learn

• Provide a complete description of the proposed use of the animals

[2.31(e)(3)]

• Describe the procedures designed to assure the pain and discomfort are 

minimized [2.31(e)(4)]

• Describe the method(s) of euthanasia to be used [2.31(e)(5)]

In addition, the IACUC must determine that any proposed activities meet the 

following requirements: 

• Procedures involving animals will avoid or minimize discomfort, distress, or 

pain to the animal [2.31(d)(1)(i)]

• The Principal Investigator (PI) considered alternatives to procedures that 

cause more than momentary or slight pain or distress, and

• The PI has provided a written narrative description of the methods and 

sources used to determine that alternatives were not available [2.31(d)(1)(ii)] 

• There is a written assurance from the principal investigator that the 

proposed activities do not unnecessarily duplicate previous experiments 

[2.31(d)(1)(iii)]

• Procedures that cause more than momentary or slight pain or distress will 

NOTICE

The description should be clear enough to be easily understood by the 

IACUC’s outside member.
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[2.31(d)(1)(iv)]:

o Be performed with appropriate sedatives, analgesics, or anesthetics, 

unless justified for scientific reasons, in writing, by the PI and will 

continue for only the necessary period of time

o Involve, in their planning, consultation with the attending veterinarian or 

his or her designee

o Not include the use of paralytics without anesthesia

• Animals that would otherwise experience severe or chronic pain or distress 

that cannot be relieved will be painlessly euthanized at the end of the 

procedure or, if appropriate, during the procedure [2.31(d)(1)(v)]

• The animals’ living conditions are appropriate for their species in accordance 

with part 3 [2.31(d)(1)(vi)]

• The animals’ housing, feeding, and nonmedical care will be directed by the 

attending veterinarian or other qualified scientist trained and experienced in 

the proper care, handling, and use of the species being maintained or studied 

[2.31(d)(1)(vi)]:

• Medical care for animals will be available and provided as necessary by a 

qualified veterinarian [2.31(d)(1)(vii)] 

• All personnel who will be conducting the proposed activities on theanimals 

are qualified and trained [2.31(d)(1)(viii)]

• Activities that involve surgery[2.31(d)(1)(ix)]:

o Include appropriate provision for pre-operative and post-operative care 

of the animals in accordance with established veterinary medical and 

nursing practices

o All survival surgery will be performed using aseptic procedures, including 

surgical gloves, masks, sterile instruments, and aseptic techniques

o Major operative procedures on non-rodents will be conducted only in 

facilities intended for that purpose which shall be operated and 

maintained under aseptic conditions

o Non-major operative procedures and all surgery on rodents do not 

require a dedicated facility, but must be performed using aseptic 

procedures

o Operative procedures conducted at field sites need not be performed in 

dedicated facilities, but must be performed using aseptic procedures

• No animal will be used in more than one major operative procedure from 

which it is allowed to recover, unless: [2.31(d)(1)(x)]

o Justified for scientific reasons by the principal investigator in writing

o Required as routine veterinary procedure or to protect the health or wellbeing of the animal as determined by the attending veterinarian, or 
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o In other special circumstances as determined by the Administrator on an 

individual basis

• Methods of euthanasia used must be in accordance with the definition of the 

term in this subchapter, unless a deviation is justified for scientific reasons, in 

writing, by the investigator [2.31(d)(1)(xi)]

Specific Types of Protocols

7.2.4.1. Painful/Distressful Procedures

When reviewing protocols involving procedures that may cause more than 

momentary or slight pain/distress/discomfort (protocols in Categories D and E), 

some areas to pay special attention to include:

• The principal investigator has considered alternatives to thepainful/ 

distressful procedure

• There is a detailed narrative describing the methods and sources used to 

determine that no alternatives to the painful/distressful procedure are 

available

• Measures used to alleviate the pain/distress are clearly stated, including:

o Drugs, dosages, routes, and frequency of administration

o Other methods may include:

- Acupuncture

- Hydrotherapy

- Hot/cold packs

o A PRN (pro re nata) or “as needed” frequency of administration is not 

acceptable unless there are detailed instructions and criteria for 

determining administration of the drug

• Availability of experienced personnel, especially at night and on weekends 

and holidays, to assess and administer pain relief

• If pain/distress relief is not to be used, there is an adequate justification and 

endpoints are described that will be used to terminate the study and/ or 

used as the basis for when treatment or euthanasia will be performed

• The principal investigator has consulted and involved the attending 

veterinarian or his/her designee in the planning of the procedure andpain/ 

distress relief

• There is not the use of paralytics without anesthesia

• Animals experiencing severe or chronic pain/distress that cannot be relieved 

will be humanely euthanized during the procedure or at the end of the 

procedure as appropriate
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7.2.4.2. Antibody Production Protocols

When reviewing protocols involving antibody production, some areas to pay 

special attention to include:

• The principal investigator has considered alternatives for painful/ distressful

procedures

• An alternative search, if done, was conducted and includes a narrative that 

describes the methods and resources considered when determining 

alternatives were not available

• The justification for the number of animals to be used was appropriate,such 

as the amount of antibody needed and the amount which can be produced 

by an animal

• There is a complete description of the procedure to induce antibody 

production and the collection of blood/serum and minimize pain and distress

7.2.4.3. Food and/or Water Deprivation or Restriction

When reviewing protocols involving food and/or water deprivation or restriction, 

some areas to pay special attention to include:

• The food/water deprivation or restriction is adequately justified

• If the animals are likely to experience distress, the principal investigator has 

considered alternatives to the distressful procedures

• Procedures used to restrict food/water are adequately described andeasily 

understood

• Procedures for selection of animals and training and monitoring the animals 

are described

• Baseline physiological data are being collected as needed

• Physiological parameters are being monitored during the study, such as:

o Body weight

o Hydration status

o Behavioral changes

NOTICE

If the research facility has written, IACUC-approved standard operating 

procedure(s) (SOPs) for such things as, but not limited to, surgical procedures, 

pain/distress relief, antibody production, routine veterinary care, housing, 

euthanasia, etc., and these specific procedures are not described in a PI’s 

submitted protocol, the PI’s protocol must reference and follow the 

applicable SOP(s).
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o Plasma osmolality

• Supportive care is provided to any animal showing signs of dehydration or

stress

• If supportive care cannot be provided, there is an appropriate scientific 

justification for not doing so

• How the animals’ daily food and water intake was determined

• The protocol addresses how the animal is to receive its required daily food or 

water intake, such as:

o During its working sessions

o Supplementation to the amount consumed during working sessions

o Whether small amounts of food or water provided as rewards are, or are 

not, considered part of the animal’s daily food or waterrequirement

• If the animal is not to receive its daily food and water requirement, 

procedures and parameters for monitoring the animal are detailed in the 

protocol

• The endpoint has been determined and identified

7.2.4.4. Neuromuscular Blockers

When reviewing protocols involving the use of neuromuscular blockers (NMB), 

some areas to pay special attention to include:

• The use of the NMB is appropriate

• The use of the NMB is adequately described in the protocol 

• The NMB is being used with general anesthesia

• All personnel working with the animal and NMB are properly trained in its 

use and possible adverse reactions

• The animal is being properly monitored, such as:

o Heart rate and blood pressure

o Not using the pain withdrawal response as it is not an appropriate 

measure of the level of anesthesia since this response would be 

prevented by the NMB

• Appropriate supportive care, such as ventilator support, is being provided 

during anesthesia

• Surgical and anesthesia records contain the appropriate information

• Recovery procedures are appropriate, i.e.:

o The animals are reversed from the NMB when reversal agents are 

available before being allowed to recover from the anesthesia

o Recovery is being monitored
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7.2.4.5. Surgical Procedures

When reviewing protocols involving surgical procedures, some areas to pay 

special attention to include:

• The pre-procedural care and surgical preparation of the animals are clearly 

stated, drugs given prior to and during the procedures, such as analgesics, 

tranquilizers, and anesthetics, are appropriate and at the correct dosage for 

the species

• The surgical procedure is stated clearly and in detail

• All survival surgeries are performed using aseptic technique

• Major operative survival surgeries on non-rodents are performed in a 

dedicated surgical facility

• No animal is being used in more than one major operative survival surgery 

unless appropriately approved

• Post-surgical procedures are stated clearly

• Pain/discomfort relief measures are stated clearly

7.2.4.6. Teaching Protocols

When reviewing teaching protocols, some areas to pay special attention to 

include:

• The rationale for the number of animals to be used was appropriate, such as 

the number of students per animal

• The principal investigator has considered alternatives to procedures that may 

cause more than momentary or slight pain or distress to the animals and has 

provided a written narrative description of the methods and sources, e.g., 

the Animal Welfare Information Center, used to determine that alternatives 

were not available. Examples of alternatives to using live animal for teaching 

include:

o Veterinary mannequins

o Live tissue alternatives

o Surgical simulators

o Virtual reality simulators

• There is a complete description of the procedures to be used

• The number of procedures to be performed on each animal is clearly stated, 

such as injections per animal

• The personnel doing the teaching are qualified and properly trained 

• If the teaching procedures cause more than momentary or slight pain or 

distress, proper methods are used to alleviate the pain/distress
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7.2.4.7. Toxicity and Vaccine Potency/Efficacy Studies

When reviewing protocols involving toxicity and vaccine potency/efficacy 

studies, some areas to pay special attention to include:

• The principal investigator has considered alternatives to procedures that may 

cause more than momentary or slight pain or distress to the animals and has 

provided a written narrative description of the methods and sources, e.g., 

the Animal Welfare Information Center, used to determine that alternatives 

were not available. Examples of alternative methods for these procedures 

include:

o Revised up-and-down procedure (UDP) as a refinement to LD50 studies 

(refinement, reduction)

o Use of cell cultures and tissue assays, such as for dermal and ocular 

safety testing

o Use of sequential testing and fewer animals to identify dermal and ocular 

chemical hazards (reduction)

• The rationale for the number of animals to be used was appropriate

• Appropriate methods are being used to relieve any pain or distress,unless 

scientifically justified

• Animal technicians and caretakers are properly trained in identifying 

problems and procedures to follow

• Humane end points for when the study can be terminated or that can be 

used as the basis for euthanasia or treatment have been determined and 

identified

Inspection Procedures

Listed below are some additional aids to assist you in determining if the 

procedures outlined in the protocols are being followed:

• Ask how the research facility keeps track of the number of animals approved 

by the IACUC and the number of animals used by the principal investigator, 

TIP

The Interagency Coordinating Committee on the Validation of Alternative

Methods provides a list of some alternative tests.

NOTICE

Animals may be held, but cannot be used, without being on a protocol.
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such as:

o Computer records

o Acquisition and disposition records

o Dead animal records

o Inventory cards

• Ask how the facility checks the accuracy of its methods for tracking the 

number of animals

• Ask for exemption/exceptions to the Regulations or Standards, then check 

the protocol to determine that the exemption/exception was approved

• Determine if the animal care staff is familiar with the protocol procedures, 

especially pre- and post-painful/distressful procedure care, such as:

o Asking the staff

o Checking the availability of protocols

o Checking the availability of standard operating procedures

o Looking in medical records

• Watch the animal care staff, principal investigators, or laboratory personnel 

handle the animals (or ask them to handle the animals, if appropriate)

• Review medical records/investigator’s logs to determine that animals with 

painful/distressful procedures received the proper pain/distress relieving 

drugs, if applicable

• Observe animals for signs of pain

• Ask about weekend staffing, animal observation, and medical care

• Determine if the medical or emergency contact numbers are current and 

readily available, such as:

o On bulletin boards

o In the animal rooms

o In medical records/charts

o In protocols

• Observe surgeries to determine that they are being conducted using aseptic 

technique and in dedicated surgical facilities, if required

• Ask how the research facility tracks animals to ensure that they are notused 

for another survival surgery (unless approved by the IACUC or APHIS), such 

as:

o Health records

o Individual animal records

o Cage cards
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o Surgery records

o Investigator’s logs

• For APHIS-approved multiple major survival surgeries, verify that the 

stipulations in the approval letter are being met

Table 7-1 Species-Typical Signs of Pain

Species Possible Signs of Pain1, 2

Dogs Quiet, unwilling to move, abnormal posture, lack of alertness, 

whimpering, groaning, howling, shivering, loss of appetite, 

increased respiration, growl or exhibit apprehension when 

approached

Cats Ungroomed appearance, quiet, apprehensive facial expression, 

loss of appetite, crying, hissing, hiding, crouching or hunching

Guinea Pigs Quiet, decreased food and water consumption, anorexia

Hamsters and 

Gerbils

Decreased activity, piloerection, ungroomed appearance

Rabbits Inactivity, appear apprehensive or anxious, hunched appearance, 

hide, squeal or cry, possible aggressive behavior with excessive 

scratching and licking

Nonhuman 

Primates

Stops eating and/or drinking, stops grooming

Cattle Dull, depressed appearance, heads bowed, lack of alertness, loss of 

appetite, rapid/ shallow breathing, rigid posture

Sheep and 

Goats

Similar to cattle, also vocalization, teeth grinding, increased lip 

curling

Pigs Changes in overall demeanor, social behavior, gait, and posture, 

unwilling to move, hiding, excessive squealing when handled

1 Excerpted from: National Research Council: Recognition and Alleviation of 

Pain in Laboratory Animals, Washington, D.C., National Academy Press,

2009.

2 These are possible signs of pain and do not necessarily mean the animal is 

in pain. A lack of thesesigns also does not mean that the animal is not in

pain.
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7.3. Veterinary Care Requirements for Dogs

7.3.1 Written Program of Veterinary Care [3.13(a)]

A research facility with dogs that has a full-time, part-time or consultant 

attending veterinarian (AV) must have a signed, written Program of Veterinary 

Care (PVC).

Each research facility with dogs must have and follow an appropriate program of 

veterinary care that is:

• Developed, and

• Documented in writing, and

• Signed by the Attending Veterinarian (full-time, part-time or consultant)

The written PVC must be:

• Kept and maintained by the research facility, and

• Made available for APHIS inspection

In addition to addressing the general requirement for adequate veterinary care 

as required in Section 2.33, the written Program of Veterinary Care for dogs 

must include: [3.13(a)]

• Regularly scheduled visits, not less than once every 12 months, by the AV to 

all premises where dogs are kept to assess and ensure the adequacy of 

veterinary care

• Complete physical examination from head to tail of each dog by the AV, not 

less than once every 12 months, as follows:

o If the research facility has had the dog for 12 months, it must have had a 

physical exam during those 12 months 

o If the research facility keeps a puppy born on the premises, it must have a 

physical exam before it is 12 months old

o If the research facility buys a dog, it must have a physical exam within the 

first 12 months of ownership, and every 12 months thereafter

• Vaccinations for contagious and/or deadly disease of dogs in accordance with 

a schedule approved by the AV, unless otherwise required by a research 

protocol approved by the IACUC, including but not limited to:

o Rabies

NOTICE

The use of the APHIS Form 7002 – Program of Veterinary Care and/or the 

APHIS Form 7002a – Program of Veterinary Care for Dogs (see Appendix A) 

is not required. However, these are useful tools to ensure that all the 

requirements are met.
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o Parvovirus

o Distemper

• Sampling and treatment for parasites and other pests in accordance with a 

schedule approved by the AV, unless otherwise required by a research 

protocol approved by the IACUC, including but not limited to:

o Fleas

o Worms

o Coccidia

o Giardia

o Heartworm

• Preventive care and treatment, unless otherwise required by a research 

protocol approved by the IACUC, to ensure:

o Healthy and unmatted hair coats

o Properly trimmed nails

o Clean and healthy:

- Eyes

- Ears

- Skin

- Teeth

7.3.2 Medical Records for Dogs [3.13(b)] 

A research facility with dogs must:

• Keep copies of medical records for dogs, and

• Make the records available for APHIS inspection

Medical records for dogs must include:

• Identity of each animal including:

o Identifying marks

o Tattoos

o Tags

o Breed

o Sex 

o Age

• If a medical problem is identified (such as disease, injury, or illness), the 

following information is required in the dog’s medical record:
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o Date the problem was identified

o Description of the problem

o Examination findings

o Test results

o Plan for treatment and care

o Treatment procedures performed, when appropriate 

• Names of all vaccines administered and the date(s) of administration

• Names of any treatment administered and the date(s) of administration

• Dates and findings/results of all:

o Screening

o Routine or other required or recommended tests

o Examinations

Medical records for dogs must be kept and maintained:

• For the duration of the research activity, and

• For an additional 3 years after the dog is euthanized or disposed of, and

• For any period in excess of 3 years as necessary to comply with Federal, 

State, or local law, and

• If notified by the APHIS Administrator in writing that specified records must 

be retained pending the completion of an investigation or proceeding under 

the Act, the records must be held until their disposition is authorized by the 

Administrator 

NOTICE

Routine husbandry (such as vaccinations, preventive medical procedures, or 

treatments) performed on all dogs in a group/herd may be kept on a single 

record.
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7.4. Contracted Research or Projects that Involve Multiple Registrants

When registered research facilities (RF) contract research out to be conducted at 

another facility, it is the responsibility of the registrants to determine which 

party is responsible for the functions of the IACUC, animal care and handling, 

and reporting of the animals on the Annual Report.

No Delegation of Responsibilities

If the research facilities have not delegated responsibilities or projects involving 

multiple registrants where there are no clearly designated areas of responsibility 

for each research facility, then:

• Both registered parties are responsible, and

• Both IACUCs should perform all required functions, and

• Only one of the RFs should report the animals on the Annual Report

• The inspector should cite both RFs for any noncompliances identified

Specific Responsibilities

If the contract designates specific responsibilities to each partner, the facility is a 

site of both registrants.

The inspector should inspect only the designated institution for the specific 

responsibility agreed upon in the contract.

For example:

• RF A is designated to perform the semiannual program review and facility 

inspection, while both RF A and RF B are designated to review the protocol, 

then:

o Both RF A and RF B are responsible for the protocol and both IACUC’s 

must approve the protocol, but

o Only RF A is responsible for the semiannual review

o The inspector inspects:

- The protocol review and approval at both RF A and RF B, and

- The semiannual review only at RF A

• The contract specifies that both RF A and RF B are responsible for the IACUC 

functions, but only RF B is responsible for the animal care and handling, and 

reporting on the Annual Report, then:

o The inspector inspects:

- The IACUC functions at RF A, and

- The IACUC functions, animal care and handling, and the AR reporting 

of the animals under the contract at RF B
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All Responsibilities Designated

• If RF A contracts the entire project and all responsibilities to RF B, then:

o The location of RF B is not a site of RF A

o RF A does not have any responsibility for the IACUC functions, animal 

care and handling or Annual Reporting

o The inspector inspects only RF B for the IACUC functions, animal care and 

handling, and Annual Reporting.

Individual researchers or staff frequently partner with multiple institutions. The 

IACUC reviewing the protocol must assure that all personnel have appropriate 

training and qualifications. [2.32(a)] But this does not confer any responsibility 

on the other RFs with which that particular individual is associated.
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7.5. Records

The research facility must maintain records of the IACUC’s activities in 

accordance with the regulations [2.35].

Required Research Facility Records

7.5.1.1. IACUC Records

A research facility must have the following records, if applicable, for review 

during inspection [2.35]:

• Minutes of the IACUC meetings, including:

o Records of attendance

o Activities conducted by the IACUC at the meeting

o Committee deliberations

• Records relating to animal activities, including:

o Proposed activities involving animals

o Proposed significant changes in activities

o Whether IACUC approval was given or withheld

• Semi-annual reports of the review of humane care and use program and the 

facility inspection which must:

o Be reviewed and signed by a majority of the IACUC members

o Include minority views

o Contain a description of the nature and extent of the research facility’s 

adherence to the AWA Regulations and Standards

o Identify specifically any departures from the Regulations and Standards

o State the reason for each departure

o Distinguish significant deficiencies from minor deficiencies

o Contain a reasonable and specific plan and schedule with dates for 

correcting each deficiency

• Record of the semi-annual reports being forwarded to the Institutional 

Official

Animal Records

A research facility must have the following records, if applicable, available for 

review during an inspection:

• Program of Veterinary Care

o Written signed program of veterinary care for dogs, if applicable 
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o Written program of veterinary care for animals other than dogs, if using 

part-time or consulting attending veterinarian

• Dogs 

o Acquisition and disposition records for dogs [2.35(b) and (c)]

o Record of animals on hand for dogs (Use of APHIS Form 7005 is not 

required.) [2.35(b)]

o Exercise plan for dogs [3.8]

o Medical Records [3.13(b)]

• Cats:

o Acquisition and disposition records for cats [2.35(b) and (c)]

o Record of animals on hand for cats (Use of APHIS Form 7005 is not 

required.) [2.35(b)]

• Nonhuman Primates:

o Environmental enhancement plan for nonhuman primates [3.81]

• Marine Mammals:

o Documentation of training of attendants or employees [3.108(b)]

o Medical records [3.110(d)]

o Necropsy records [3.110(g)]

Annual Report

Both you and the RF should have a copy of the Annual Report.

The inspector should verify that the RF’s Annual Report is accurate, that is:

• All animal facilities are reported

• Only regulated species are reported

• Animals are reported in the correct column

• IACUC-approved exceptions not provided for in AWA Regulations and 

Standards are reported

• IACUC-approved exemptions provided for in the AWA Regulations and 

Standards are not reported

• The number of animals reported is correct

• There are appropriate explanations for all Column E animals

The inspector should verify that the RF’s Annual Report does not report any 

animals used for the following:

• Laboratory rats and mice (genera Rattus and Mus) bred for use in research

• Reptiles, fish, or other mammals exempt from regulation under the AWA 
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• Animal patients participating in clinical trials in the context of medical care 

under a veterinary client relationship

• Any birds 

• Field studies which meet the following criteria and are therefore exempt 

from the Regulations and do not require a written, approved exemption. The 

study does not [1.1, 2.31(d)(1)]:

o Harm the animals under study

o Involve an invasive procedure

o Materially alter the behavior of the animals understudy

• Animals euthanized, killed, or trapped, and collected, such as for study or 

museum samples, from their natural habitat via humane euthanasia

• Agricultural research

• Food or fiber

• Wildlife management projects

Methods of verifying the animal numbers include, but are not limited to:

• Asking the research facility representative to demonstrate how the number 

of animals was determined for:

o A particular species, or

o A column from the Annual Report

• Asking for verification of animals used by site to obtain the total numberof 

animals used, for example:

o Review a particular species used by site, or

o Review a column from the Annual Report by site

• Counting the animals, if appropriate or feasible

• Review of:

o Acquisition records

o Animal ordering information, such as invoices or computer animal 

tracking systems

o Animals ordered in comparison to number of animals approved for a 

particular protocol

o Facility animal census records

o Internal billing records to PIs for animal housing/care

Animals reported in Column B of APHIS Form 7023-Annual Report, should be 

those animals being bred, conditioned, or held for use in teaching, experiments, 

research, or surgery, but not yet used for such purposes.

All animals contained on the facility’s inventory on September 30 of the 
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reporting year that were not used in a research project that year should be 

reported in Column B as being held for research purposes. Animals that were 

held but died during the year without being used for research purposes should 

also be reported in this column. Other animals held during the reporting year 

but not present at the facility on September 30 should not be reported in this 

column. They should be reported by the facility which possesses them on 

September 30.

If a research facility is licensed as a dealer:

• Breeding animals and any offspring intended for research purposes within 

the research facility should be reported in Column B

• Animals intended for sale only should not be reported in Column Bbut 

should be included on the dealer license renewal

• If the research facility is unsure of the status of an animal (research or sale 

only), the animal should be reported in Column B

Animals actually used for research purposes during the reporting year must be 

reported in Column C, D, or E, as appropriate. [2.36(b)(5-7)]

The use of anesthesia does not always mean that the animal should be reported 

in Column D:

• If an animal being housed, held, or bred (Column B) was anesthetized for a 

non-invasive procedure, a blood draw, or other veterinary care procedure, 

the animal could still be reported in Column B

• If a Column C research animal was anesthetized for a non-invasive 

procedure, a blood draw, or other veterinary care procedure, the animal 

could still be reported in Column C 

• The research facility should determine the appropriate reporting Column

•

If an animal was moved to another RF during the reporting year, the animal 

should only be reported once by either:

• The RF with the highest pain category for the animal, or

• If the pain categories are the same, then by the last RF to possess the animal

Refer to the following document and the AC Website for additional information 

about the Annual Report:

• APHIS Form 7023–Annual Report of Research Facility

• https://www.aphis.usda.gov/aphis/ourfocus/animalwelfare/SA_Obtain_Rese

arch_Facility_Annual_Report

NOTICE

If methods other than anesthetics, analgesics, or tranquilizing drugs are used 

to relieve pain or distress, animals can still be reported in Column D if the 

methods are appropriate and effective.
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• To submit an Annual Report online, go to: 

https://www.aphis.usda.gov/aphis/ourfocus/animalwelfare/SA_Obtain_Rese

arch_Facility_Annual_Report

7.5.3.1. Exceptions or Exemptions

Exceptions or exemptions to a particular AWA Regulation or Standard approved 

by the IACUC must be [2.36(b)(3)]:

• Specified, and

• Explained by the principal investigator

If a Regulation or Standard provides specific parameters for an exemption, those 

parameters must be followed. 

Exceptions that should be reported on the Annual Report:

• Exceptions approved by the IACUC under 2.38(k) that are not provided for 

under the Regulations and Standards, including but not limited to:

o Removal of resting platforms from cat enclosures

o Extension of interval for cleaning/sanitization of enclosures

o Keeping animals in 24-hour dark cycle

o Keeping animals in temperatures outside range described in Part 3—

Standards for species

The following should not be reported as exceptions on the Annual Report:

• Exceptions approved by the IACUC that are provided for under the 

Regulations and Standards, including but not limited to:

o Approval for use of an animal in more than one major operative 

procedure from which it is allowed to recover on one protocol 

[2.31(d)(1)]

o Short term withholding of food and water from animals[2.38(f)(2)]

o Exemption of an individual NHP from some or all of the environmental 

enhancement plan [3.81(e)(2)]

o Any deviation from euthanasia, as defined in the AWA Regulations, which 

was justified for scientific reasons, in writing, by the investigator

[2.31(d)(1)(xi)]

o Withholding of water from an NHP if required by the research protocol 

approved by the IACUC [3.83]

• Procedures required as part of the provision of veterinary care, including but 

not limited to:

o Animal is fasted or water is restricted prior to surgery

o Animal is housed in an enclosure that does not meet space requirements 

for medical reasons while recovering from husbandry or veterinary care 
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related surgery

o Animal develops vomiting/diarrhea (not study related) and veterinarian 

prescribes IV fluids and severely restricts food and water intake by mouth 

for several days

Retention

All records and required reports must be maintained [2.35(f)]:

• At least 3 years, or

• Longer if:

o Necessary to comply with any applicable Federal, State, or local law

o The APHIS Administrator notifies the research facility, in writing, that 

specified records must be retained pending completion of an 

investigation or proceeding and held until their disposition isauthorized

Records must be held for at least 3 years from the date of completion of the 

IACUC-approved protocol [2.35(f)].

Availability

Records must be available for inspection and copying by any APHIS official

[2.35(f), 2.38(a), 2.38(b)(1)(ii) and (iii)]

Also, records retained under 2.35 must be made available for inspection and 

copying by any funding Federal agency representative

Confidentiality and Removal of Records

APHIS inspectors must [2.35(f)]:

• Maintain the confidentiality of the information

• Not remove the records from the research facility’s premises unless:

o There has been an alleged violation

o The records are needed to investigate a possible violation

o The records are needed for other enforcement actions

The inspector should follow the guidelines below when removing records from a 

research facility:

• Only take photos or copies of records off-site if needed to support a Direct, 

NOTICE

Release of any materials removed from the facility that contain trade secrets, 

or commercial or financial information that is privileged or confidential, will 

be governed by applicable sections of the Freedom of Information Act.
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Critical or Repeat citation, or when there is a disagreement between you and 

the research facility over an NCI and the research facility has indicated that it 

is likely to appeal the citation. Do NOT remove original records.

• Make copies or scan records, instead of photographing, if possible

• Be sure the research facility knows what records were copied, scanned, 

and/or photographed before leaving the facility

• Give the research facility the opportunity to redact names, locations, and 

other PII before taking photos, scanning, or making copies of the record. You 

should allow the facility 24 to 48 hours for thisredaction.

• Provide the research facility the opportunity to view your photos. Delete or 

retake any photos that the facility states may contain potential PII, or 

confidential or proprietary information to remove or block the sensitive 

information. If the noncompliance cannot be documented without the 

inclusion of potentially confidential or proprietary information, ensure that 

the photograph label states: “May contain confidential or proprietary

information.”

SACS may have inspectors take additional photographs, in addition to the 

required photos listed above.
--- Animal Care Inspection Guide ---

Savedate 12/7/2021 9:38 AM Research Facility Inspection 7-36

7.6. Guidance for Veterinary Schools and Veterinary Technician Programs (VTP) for the 

Inspector

Teaching versus Research

The definition of activity in Part 1 of the AWA means, those elements of 

research, testing, or teaching procedures that involve the care and use of 

animals.

For the purposes of the AWR, teaching is equivalent to research. Using farm 

animals for teaching related to food or fiber, or breeding, management or

production efficiency is not regulated. Using farm animals for teaching related 

to basic science or biomedical research is regulated. 

Inspection Procedures

The inspector should only inspect the animals and animal facilities for animals 

owned by the facility.

Do not inspect animals or housing areas for animals owned by other entities 

such as vet clinics, hospitals, or shelters.

For Veterinary School Spay/Neuter Programs, IACUC oversight is not required if 

the Veterinary School has a written agreement with a pound/shelter, which is 

acting as the owner of the animals, soliciting the service of the Veterinary School 

to perform spaying/neutering. 

If the facility asks you to inspect or look at non-regulated animals or facilities, 

you may go through these areas with the facility representative but do not 

document any findings on an Inspection Report. Consult your SACS if further 

guidance is necessary.

7.6.2.1. Records Requirements

For regulated animals used in regulated teaching activities, the records 

requirements are the same as for any other research facility.

The following records must be available for review during the inspection, if 

applicable:

• Acquisition/disposition records must be kept for any dogs or cats acquired by 

the facility that do not fall under a veterinary client patient relationship. The 

use of APHIS Forms 7005 and 7006 are not required but may be used by the 

facility to keep and maintain the required information. [2.35(b)]

Acquisition/disposition records are not required for:

• Dogs/cats who are patients of the Veterinary or Veterinary Technician school

• All regulated animals other than dogs and cats

All regulated species of animals used for regulated purposes must be included on 

the Annual Report. [2.36(b)(5-8)]
--- Animal Care Inspection Guide ---

Savedate 12/7/2021 9:38 AM Research Facility Inspection 7-37

The following animals should not be included on the Annual Report:

• Client, staff, or student-owned animals 

• Animals utilized for teaching purposes at working farms, ranches, veterinary 

hospitals or shelters 

Records must be held for at least three years (beyond the final disposition of the

animal) [2.35(f)].

7.6.2.2. Identification Requirements

For regulated animals used in regulated teaching activities, the animal 

identification requirements are the same as for any other research facility.

Research facilities are only required to individually identify dogs and cats. 

[2.38(g)].

There are no individual identification requirements for other regulated species.

7.6.2.3. Protocols

For protocols involving regulated animals used in regulated teaching activities, 

protocol and IACUC oversight requirements are the same as for any other 

research facility.

For animals that are not regulated by the AWA (i.e., pets or patients) no 

protocols or IACUC oversight is required.

Special Considerations

Contact your SACS if any of these circumstances come to your attention via 

inspection or another method:

• Complaints are received regarding the welfare of the animals

• Inspector becomes aware of animal injury or death as the result of nonregulated teaching procedures

• The owner of an animal expresses concern about its care or use
--- Animal Care Inspection Guide ---

Savedate 12/7/2021 9:38 AM Research Facility Inspection 7-38

7.7. Inactive Research Facility or Research Facility with No Activity for Two Years 

Inspection

Inactive Research Facility

A research facility may request to be placed in an inactive status if the research 

facility has:

• Made a written request to the Animal Welfare Operations Director, and

• Not used, handled, or transported regulated animals for a period of atleast 

two years

An inactive research facility must [2.30(c)(2)]:

• File an Annual Report of its status

• Notify the Animal Welfare Operations Director, in writing, at least ten days 

prior to using, handling, or transporting regulated animals again

Research Facilities with No Regulated Activity for Two Years

Inspect an active research facility which has not conducted any regulated activity 

for at least two years the same as an inactive research facility even though the 

research facility has not requested inactive status.

7.7.2.1. Inspection Frequency

Inactive research facilities and research facilities with no activity for two years 

are inspected at least annually.

Contact your SACS if you are unable to inspect a facility during the required 

period.

7.7.2.2. Inspection Procedures

The inspector should inspect records and facilities to confirm that the research 

facility has not used, handled, or transported any regulated species and has not 

conducted any regulated activity since your last inspection, then:

• Categorize the Inspection Report as a "Routine" 

• Document on the Inspection Report, “No regulated activities”

• Encourage the research facility to cancel its registration

• Ensure that the research facility has an IACUC in place and has filed an 

Annual Report
--- Animal Care Inspection Guide ---

Savedate 12/7/2021 9:38 AM Research Facility Inspection 7-39

NOTICE

Remind the inactive research facility that it must notify the Animal Welfare 

Operations Director, in writing, at least 10 days prior to using, handling, or 

transporting regulated animals again. [2.30(c)(2)]
--- Animal Care Inspection Guide ---

Savedate 12/7/2021 9:38 AM Research Facility Inspection 7-40

7.8. Holding Period

Research facilities that acquire dogs or cats from sources other than dealers, 

exhibitors, and exempt sources must hold the animals for a full 5 days after 

acquiring the animals, not including the day of acquisition and time in transit, 

before the facility may use the animals. [2.38(j)]
--- Animal Care Inspection Guide ---

Savedate 12/7/2021 9:38 AM Research Facility Inspection 7-41

7.9. Research Facility Protocol Selection Worksheet
--- Animal Care Inspection Guide ---

Savedate 12/7/2021 9:38 AM List of Appendices 1

Appendices

Tip: Depending on your application settings, you may have to use CTRL-click to use 

hyperlinks.

Contents

Forms and Worksheets A-1

General Information B-1

NCI/Direct/Critical Noncompliance Examples C-1

Equipment and Supplies D-1

Body Condition and Size Charts E-1

Acronyms F-1

Index 1
--- Animal Care Inspection Guide ---

Savedate 12/7/2021 9:38 AM Forms and Worksheets A-1

Forms and Worksheets

Contents

Official APHIS Forms A-2

Amended Inspection Report Letter A-3

Attempted Inspection Checklist A-4

Attempted Inspection Leave-Behind Flyer A-5

Attempted Inspection Letter and Enclosure A-6

Attempted Inspection – Script Following an Attempted Inspection A-8

Complaint Worksheet Error! Bookmark not defined.

Environmental Enrichment Plan Inspection Checklist A-13

Facility Contact Worksheet A-15

Inspection Report Review Checklist A-16

Search for Unlicensed Activity Worksheet A-18

Teachable Moments Review Checklist A-19

Unsatisfactory Optimal Hours Response Letter A-21
--- Animal Care Inspection Guide ---

Savedate 12/7/2021 9:38 AM Forms and Worksheets A-2

Official APHIS Forms

These forms listed below are linked to the current versions on the Animal Care 

external website. Depending on your application settings, you may need to hold 

down the CRTL key when you click on them. Note that the links below for Forms

7003, 7003 A, 7011, 7011 A will bring the user to the site "Regulated Businesses 

– Request a License/Registration Application Kit" where the user will choose 

which form is applicable to their situation.

APHIS Form 7002 – Program of Veterinary Care

APHIS Form 7002 A - Animal Care - Program of Veterinary Care for Dogs

APHIS Form 7003 - Application for License (Renewal)

APHIS Form 7003 A – Application for License (New)

APHIS Form 7005 – Record of Acquisition of Dogs and Cats

APHIS Form 7006 – Record of Disposition of Dogs and Cats

APHIS Form 7006A – Continuation Sheet for Record of Disposition of Dogs and 

Cats

APHIS Form 7011 – Application for Registration - Registration Update

APHIS Form 7011A – Application for Registration Package

APHIS Form 7019 – Record of Animals on Hand (Other than Dogs and Cats)

APHIS Form 7020 – Record of Acquisition, Disposition or Transport of Animals 

(Other Than Dogs and Cats)

APHIS Form 7023 – Annual Report of Research Facility

Annual report information and forms can be found on our website at:

https://www.aphis.usda.gov/aphis/ourfocus/animalwelfare/SA_Obtain_Research_Facili

ty_Annual_Report

APHIS Form 7023A - Continuation Sheet for Annual Report of Research Facility

APHIS 7050 – Environmental Enhancement Program for Non-Human Primates
--- Animal Care Inspection Guide ---

Savedate 12/7/2021 9:38 AM Forms and Worksheets A-3

Amended Inspection Report Letter
--- Animal Care Inspection Guide ---

Savedate 12/7/2021 9:38 AM Forms and Worksheets A-4

Attempted Inspection Checklist
--- Animal Care Inspection Guide ---

Savedate 12/7/2021 9:38 AM Forms and Worksheets A-5

Attempted Inspection Leave-Behind Flyer
--- Animal Care Inspection Guide ---

Savedate 12/7/2021 9:38 AM Forms and Worksheets A-6

Attempted Inspection Letter and Enclosure
--- Animal Care Inspection Guide ---

Savedate 12/7/2021 9:38 AM Forms and Worksheets A-7
--- Animal Care Inspection Guide ---

Savedate 12/7/2021 9:38 AM Forms and Worksheets A-8

Attempted Inspection – Script Following an Attempted Inspection 
--- Animal Care Inspection Guide ---

Savedate 12/7/2021 9:38 AM Forms and Worksheets A-9
--- Animal Care Inspection Guide ---

Savedate 12/7/2021 9:38 AM Forms and Worksheets A-10
--- Animal Care Inspection Guide ---

Savedate 12/7/2021 9:38 AM Forms and Worksheets A-11
--- Animal Care Inspection Guide ---

Savedate 12/7/2021 9:38 AM Forms and Worksheets A-12

Complaint Worksheet

(For internal use only)
--- Animal Care Inspection Guide ---

Savedate 12/7/2021 9:38 AM Forms and Worksheets A-13

Environmental Enrichment Plan Inspection Checklist
--- Animal Care Inspection Guide ---

Savedate 12/7/2021 9:38 AM Forms and Worksheets A-14
--- Animal Care Inspection Guide ---

Savedate 12/7/2021 9:38 AM Forms and Worksheets A-15

Facility Contact Worksheet
--- Animal Care Inspection Guide ---

Savedate 12/7/2021 9:38 AM Forms and Worksheets A-16

Inspection Report Review Checklist
--- Animal Care Inspection Guide ---

Savedate 12/7/2021 9:38 AM Forms and Worksheets A-17
--- Animal Care Inspection Guide ---

Savedate 12/7/2021 9:38 AM Forms and Worksheets A-18

Search for Unlicensed Activity Worksheet

(For APHIS Internal Use Only)
--- Animal Care Inspection Guide ---

Savedate 12/7/2021 9:38 AM Forms and Worksheets A-19

Teachable Moments Review Checklist
--- Animal Care Inspection Guide ---

Savedate 12/7/2021 9:38 AM Forms and Worksheets A-20
--- Animal Care Inspection Guide ---

Savedate 12/7/2021 9:38 AM Forms and Worksheets A-21

Unsatisfactory Optimal Hours Response Letter
--- Animal Care Inspection Guide ---

Savedate 12/7/2021 9:38 AM General Information B-1

General Information

Contents

Dangerous, Potentially Dangerous, and Special License Animals B-2

Options for Identification of Dogs and Cats B-3

Personally Identifiable Information (PII) Examples B-4

State and Territory Identification Codes B-5
--- Animal Care Inspection Guide ---

Savedate 12/7/2021 9:38 AM General Information B-2

Dangerous, Potentially Dangerous, and Special License Animals

Section Title Topic Designation Animal Group Animal

2.1(b)(2)(ii) Licensing Requirements 

and Application

Special 

license 

needed

Wild and exotic 

felids

Lions, tigers, leopards, cheetahs, 

jaguars, cougars, lynx, servals, 

bobcats, caracals, and any hybrids 

between these animals

Hyenas and/or 

wild and exotic 

canids

Hyenas, wolves, coyotes, foxes, and 

jackals

Bears All

Megaherbivores Elephants, rhinoceroses, 

hippopotamuses, giraffes, and 

others per AC

Group 5 

nonhuman 

primates

Baboons and non-brachiating 

species larger than 33 lbs.

Group 6 

nonhuman 

primates

Great apes over 55 lbs. and 

brachiating species

2.131(d)(3) Handling Public contact Dangerous Lions

Tigers

Wolves

Bear

Elephants

Others per AC

3.127(d) Perimeter 

fence

Perimeter 

fence height

Potentially 

dangerous

Large felid

Bears

Wolves

Rhinoceros

Elephants

Others per AC

Large felids:

Lions

Tigers

Leopards

Cougars

Others per AC

3.140 Care in 

transit

Transport 

standard

Otherwise 

dangerous

Wild or otherwise 

dangerous

None listed
--- Animal Care Inspection Guide ---

Savedate 12/7/2021 9:38 AM General Information B-3

Options for Identification of Dogs and Cats
--- Animal Care Inspection Guide ---

Savedate 12/7/2021 9:38 AM General Information B-4

Personally Identifiable Information (PII) Examples

Personally Identifiable Information (PII) is information that can be used to uniquely identify an 

individual. The following are some examples of data which when combined with an individual’s name 

constitute PII. For a decision on other data elements not indicated on this list, contact the USDA Chief 

Privacy Officer. Examples include:

• Bank account numbers

• Biometric record (such as 

fingerprint, iris scan, DNA)

• Date of birth

• Credit card numbers

• Criminal history

• Employment information to 

include ratings, disciplinary 

actions, performance 

elements and standards

• Financial information

• Medical history information 

(including medical 

conditions and metric

information, e.g., weight, 

height, blood pressure)

• Mother’s maiden name

• Place of birth

• Security clearance history or 

related information (not 

including actual clearances 

held)

• Social security number

The identification of PII requires an analysis of material in context.1

The following examples, taken alone, would generally not constitute PII. Please consult the USDA Chief 

Privacy Officer for additional guidance. 

• Academic information 

(credentials, areas of study)

• An individual’s name

• Digital pictures

• EIN/TIN as a business 

identifier

• Email addresses (work and 

personal)

• Employee present and past 

grades (and salary privacy)2

• Employee present and past 

position titles and 

occupational series2

• Phone numbers (work, 

home, cell)

• Resumes, unless they 

include an SSN

• Security clearances held

• Street addresses (work and 

personal)

• Written biographies (like the 

ones used in pamphlets or 

speakers)

1 OMB’s Memorandum, M-07-16 (of May 22, 2007, “Safeguarding and Responding to the Breach of 

Personally Identifiable Information”) requires an analysis of PII in context: “For example, an office 

rolodex contains personally identifiable information (name, phone number, etc.). In this context the 

information probably would not be considered sensitive; however, the same information in a database 

of patients at a clinic which treats contagious disease probably would be considered sensitive 

information. Similarly, using a best judgment standard, discarding a document with the author’s name 

on the front (and no other personally identifiable information) into an office trashcan likely would not 

warrant notification to US-CERT.

2 OPM Regulation, 5 C.F.R. § 293.311 states that the following information “about most present and 

former Federal employees, is available to the public: (1) Name; (2) Present and past position titles and 

occupational series; (3) Present and past grades; (4) Present and past annual salary rates ... (5) Present 

and past duty stations; and (6) Position descriptions, identification of job elements, and those 

performance standards (but not actual performance appraisals) that the release of which would not 

interfere with law enforcement programs or severely inhibit agency effectiveness..."
--- Animal Care Inspection Guide ---

Savedate 12/7/2021 9:38 AM General Information B-5

State and Territory Identification Codes

Alphabetical List Numerical Order List

64 ALABAMA 11 MAINE

96 ALASKA 12 NEW HAMPSHIRE

86 ARIZONA 13 VERMONT

71 ARKANSAS 14 MASSACHUSETTS

93 CALIFORNIA 15 RHODE ISLAND

84 COLORADO 16 CONNECTICUT

16 CONNECTICUT 21 NEW YORK

50 DELAWARE 22 NEW JERSEY

58 FLORIDA 23 PENNSYLVANIA

67 GEORGIA 31 OHIO

97 GUAM 32 INDIANA

95 HAWAII 33 ILLINOIS

82 IDAHO 34 MICHIGAN

33 ILLINOIS 35 WISCONSIN

32 INDIANA 41 MINNESOTA

42 IOWA 42 IOWA

48 KANSAS 43 MISSOURI

61 KENTUCKY 45 NORTH DAKOTA

72 LOUISIANA 46 SOUTH DAKOTA

11 MAINE 47 NEBRASKA

69 MARIANA ISLANDS 48 KANSAS

51 MARYLAND 50 DELAWARE

14 MASSACHUSETTS 51 MARYLAND

34 MICHIGAN 52 VIRGINIA

41 MINNESOTA 54 WEST VIRGNIA

65 MISSISSIPPI 55 NORTH CAROLINA

43 MISSOURI 56 SOUTH CAROLINA

81 MONTANA 57 GEORGIA

47 NEBRASKA 58 FLORIDA

88 NEVADA 61 KENTUCKY

12 NEW HAMSHIRE 63 TENNESSEE

22 NEW JERSEY 64 ALABAMA

85 NEW MEXICO 65 MISSISSIPPI

21 NEW YORK 69 MARIANA ISLANDS

55 NORTH CAROLINA 71 ARKANSAS

45 NORTH DAKOTA 72 LOUISIANA

31 OHIO 73 OKLAHOMA

73 OKLAHOMA 74 TEXAS

92 OREGON 81 MONTANA

23 PENNSYLVANIA 82 IDAHO

94 PUERTO RICO 83 WYOMING

15 RHODE ISLAND 84 COLORADO

56 SOUTH CAROLINA 85 NEW MEXICO

46 SOUTH DAKOTA 86 ARIZONA

63 TENNESSEE 87 UTAH

74 TEXAS 88 NEVADA

87 UTAH 91 WASHINGTON

13 VERMONT - 92 OREGON

52 VIRGINIA 93 CALIFORNIA

91 WASHINGTON 94 PUERTO RICO

54 WEST VIRGINIA 95 HAWAII

35 WISCONSIN 96 ALASKA

83 WYOMING 97 GUAM
--- Animal Care Inspection Guide ---

Savedate 12/7/2021 9:38 AM NCI/Direct/Critical Noncompliance Examples C-1

NCI/Direct/Critical Noncompliance 

Examples

Contents

Examples for Dogs and Cats C-2

Examples for Other Animals C-13
--- Animal Care Inspection Guide ---

Savedate 12/7/2021 9:38 AM NCI/Direct/Critical Noncompliance Examples C-2

These examples are intended to assist the inspector when determining if an issue identified is a NonCritical NCI, a Direct NCI, or a Critical NCI. A “Direct” noncompliance is a Critical noncompliance that is 

currently (at the time of the inspection) having a serious or severe adverse effect on the health and 

well-being of the animal.

This is not a complete list of possible NCIs; these are representative of the types of NCIs that may be 

identified. If you are unsure if an issue is an NCI and a Direct or a Critical, contact your SACS. 

If an issue is identified as a non-critical NCI, the inspector should determine if it meets the criteria for a 

Teachable Moment or should be cited on the Inspection Report. 

Any issue that does not rise to the level of an NCI is in compliance.

Examples for Dogs and Cats

Section 2.40 - Attending Veterinarian and Adequate Veterinary Care and Section 3.13 Veterinary 

Care for Dogs

The Veterinary Care Flow Chart should be followed for all applicable decisions regarding veterinary 

care citations. The main purpose of this chart is to assist the inspector in distinguishing between a noncritical, Direct, or Critical NCI. 

If a licensee or registrant can demonstrate via records or other means that he/she has taken the 

proper steps to mitigate the injury and/or death of the animal, a noncompliance has not occurred:

• These proper steps include, but are not limited to:

o Identifying the condition requiring veterinary care in a timely manner,

o Acquiring veterinary care and/or initiating treatment in a timely manner, 

and/or

o Following the treatment instructions of the Attending Veterinarian

Condition NCI Direct Critical

Nails Nails that are changing the 

shape of foot (e.g. pushing 

toes upwards, twisting 

toes), nails curling around 

wire floor (likely to be 

stuck), nails causing an 

alteration of the animal’s 

gait.

Nails embedded in the paw pads;

nail(s) broken past quick with 

evidence of other long nails. 

Significant alteration in animal’s 

gait or posture (3-legged lame).

Eyes 

(cherry eye)

A cherry eye with mild to 

moderate inflammation 

(i.e. redness, swelling, 

and/or mild to moderate 

clear discharge) or a large 

cherry eye (over 

iris/affecting vision)

Dog is demonstrating irritation 

(i.e. pawing at eye, squinting). A 

cherry eye associated with severe 

inflammation of the conjunctiva, 

marked discharge or mucoid 

(yellow-green) discharge, foreign 

material caked on cherry eye, 

and/or ulcerated cherry eye
--- Animal Care Inspection Guide ---

Savedate 12/7/2021 9:38 AM NCI/Direct/Critical Noncompliance Examples C-3

Condition NCI Direct Critical

Eyes (other) An eye problem (cloudy 

eye, small eyelid mass, 

entropion (rolling of the 

eyelid), etc.) with mild to 

moderate serous (clear) 

discharge and/or mild to 

moderate conjunctival 

inflammation (redness, 

swelling), corneal ulcer 

with mild to moderate 

corneal swelling/edema, 

serous (clear) discharge, 

and/or conjunctival 

inflammation. 

Microphthalmia or 

Anophthalmia (small or 

missing eye) with mild to 

moderate serous or 

mucoid discharge.

Marked/severe inflammation 

(redness and/or swelling) of the 

conjunctiva or cornea, significant 

mucoid (yellow-green discharge), 

marked serous (clear) discharge, 

dog is demonstrating irritation 

(i.e. pawing at eye, squinting).

Chronic Entropion (i.e. with 

mucoid discharge, pawing, 

squinting, or obvious corneal

ulceration).

Microphthalmia or Anophthalmia 

(small or missing eye) with severe 

serous or mucoid discharge as 

well as physical signs such as 

pawing, squinting, or an obvious 

injury.

Interdigital 

Cysts

Cysts with active 

inflammation (red, 

swollen). Cysts where the 

skin appears moist / 

edematous. The vet care 

flow chart should be 

followed – for example, 

kennels with an overall 

good program of foot care 

& documentation of prior 

identification & treatment, 

where the licensee missed 

one dog with a cyst that 

would otherwise fall in the 

regular NCI category may 

not be cited. If this 

occurs, talk to the breeder 

about initiating treatment 

per the AV’s 

recommendations. 

Multiple animals with cysts 

at a kennel where the 

licensee has not talked to 

the AV about a 

management program or 

ways to avoid cysts (or the 

Licensee is not following 

the AV’s advice) may be 

cited. 

Cysts causing lameness. 

Cysts that the dogs are actively 

licking / appear painful.

Cysts that are bleeding / bloody.
--- Animal Care Inspection Guide ---

Savedate 12/7/2021 9:38 AM NCI/Direct/Critical Noncompliance Examples C-4

Condition NCI Direct Critical

Matted Hair Lots of individual mats (i.e. 

high percent of the body & 

estimate size in report 

narrative), matted hair 

that is slightly wet or dirty 

(not freezing conditions), 

matted hair that is twisted 

and you can see the skin 

slightly being pulled / 

corded. Follow the vet 

care flow chart. For 

example, lack of a program 

for dealing with matted 

hair / regular grooming 

with multiple dogs 

affected may be cited, but 

one or two dogs may not 

be. 

Coalescing or large/thick mats 

(large areas), underlying skin 

problems (red, wet, etc.), 

significant amount of feces, urine 

or marked foreign material in 

mats, severe matting in wet 

and/or cold conditions (e.g. 

outdoor dogs in snow).

Skin Alopecia with abnormal 

skin (crusty lesions, scabs, 

dandruff, thickened skin, 

etc.).

Significant alopecia with or 

without abnormal skin 

(estimate size) in report 

narrative).

Dog is scratching and/or 

chewing various parts of 

the body frequently 

enough that it is 

interfering with normal 

behavior. Dog appears 

uncomfortable; can’t sit or 

lay down without 

returning to the 

scratching/chewing.

Skin lesions (alone or associated 

with alopecia) with active 

scratching, chewing, vocalizing,

or showing other signs of 

discomfort or distress.

Ears Mild to moderate head tilt 

or circling without other 

signs.

Mild to moderate ear 

discharge or odor WITH 

one or more of these mild 

to moderate signs: head 

shaking, ear scratching, 

vocalization, or reluctance 

to have ear examined.

Fly bite ears without the 

additional clinical signs 

listed above.

Marked ear discharge or odor 

WITH one or more of these 

severe signs: head shaking, ear 

scratching, vocalization, or 

reluctance to have ear examined, 

severe discharge / purulent 

discharge (e.g. running down face 

or head), aural hematoma’s 

resulting from head shaking (i.e. 

with excessive discharge), head 

tilt / circling, head tilt / circling w/ 

loss of body condition.

Note: These severe signs alone 

(without ear discharge and odor) 

may also be considered a direct. 

Fly bite ears with associated 

severe inflammation, severe 

discharge, scratching, and/ or 

hematoma.
--- Animal Care Inspection Guide ---

Savedate 12/7/2021 9:38 AM NCI/Direct/Critical Noncompliance Examples C-5

Condition NCI Direct Critical

Teeth Mild to moderate tartar 

and associated gingivitis 

(red, swollen gums, minor 

bleeding). Recessed gums 

with loose teeth, foul 

odor, and swelling.

Severe tartar and associated 

gingivitis with severe redness and 

swelling, loose teeth, significant 

bleeding gums, foul odor; teeth 

completely encased in a rock of 

tartar and/or significant debris 

(hair, food, etc.) entrapped in the 

teeth/gumline; presence of 

pus/discharge with a strong odor; 

physical signs such as weight loss 

or excessive salivation or 

behavioral signs such as pawing 

at the face/head, drooling, 

hiding, head shyness; draining 

tracts from the mouth to the 

surface of the head/face with 

active discharge. 

Tick/Flea 

Infestation

Light to moderate flea or 

tick infestation without 

clinical signs.

Heavy tick/ flea infestation (i.e. a 

high number of external parasites 

are visible) with associated 

evidence consistent with 

scratching and/or chewing, 

lethargy, pale mucous 

membranes, and/or labored 

breathing

GastrointestinalMild to moderate loose 

stools with no explanation 

provided by the 

licensee/registrant (diet 

change, recent treatment), 

or if the 

licensee/registrant states 

that the loose stools have 

occurred for greater than 2 

days without intervention.

There may be some drops 

of blood/mucus, the dog 

may be slightly 

depressed/lethargic.

Stools that are severely loose, 

bloody, or watery and are 

associated with an anorexic, 

emaciated and/ or moderately to 

severely lethargic dog(s).

Respiratory Bright, alert animal with 

occasional but recurring 

cough.

Moderate amount of 

serous discharge from eyes 

or nose.

Ongoing respiratory condition 

with severe cough, labored 

breathing, and/ or severe 

abnormal (purulent or yellowgreen) nasal or eye discharge. 

May be associated with anorexia 

(i.e. thin dog) and/or lethargy. 

Infectious 

disease

See individual body 

systems (i.e. respiratory, 

gastro-intestinal) for 

guidance. 

Presence of a contagious disease, 

such as parvovirus infection, with 

associated severe symptoms and 

no isolation area to seclude the 

affected dogs from the rest of the 

kennel.
--- Animal Care Inspection Guide ---

Savedate 12/7/2021 9:38 AM NCI/Direct/Critical Noncompliance Examples C-6

Condition NCI Direct Critical

Wounds Minor injuries, puncture 

wounds from dog fights.

Any untreated, prolapsed, open 

lesion/ wound where the skin is 

pulled back to expose underlying 

tissue, muscle, bone. Any 

untreated puncture wounds with 

large swelling and obvious 

discomfort (crying when touched, 

pulling away when touched, 

lethargy, anorexia). Large or 

severe wounds with signs of 

severe infection 

(purulent/yellow-green 

discharge) or excessive bleeding. 

NOTE: 

• All example conditions do not need to be present to be able to cite.

• Verbally remind the licensee that it would be beneficial to the inspection process for the licensee to have 

instructions for chronic conditions from the AV (not mandatory to have in writing from AV). 

Section 2.130 - Minimum Age Requirements

Minimum Age 

Requirements

While reviewing 

transportation 

documentation a puppy is 

noted that is too young to 

have been weaned upon 

transfer has been 

transported without the 

dam. Transportation of a 

dog or cat that has not 

been weaned, without 

their dam or queen, and 

without appropriate 

variances or exceptions (if 

required).

Transportation of a dog or cat 

that has not been weaned, 

without their dam or queen, and 

without appropriate variances or 

exceptions (if required) and 

animals are experiencing an 

adverse effect (loss of weight, 

crying, anorexia, lethargy).

Transportation of a dog or cat that 

had not been weaned, without their 

dam or queen, and without 

appropriate variances or exceptions 

(if required) and animals experienced 

an adverse effect. 

Section 2.131 – Handling of Animals (Dogs and Cats)

See examples in NCI Examples for Other Animals

Section 3 – Standards for Dogs and Cats

Section 3.1(a)

Housing 

Facilities, 

general, 

structure, 

construction

Structural deterioration, 

such as rusted support 

posts, where the structure 

is not a potential to fall on 

animals.

Structure deterioration, such as 

rusted support posts, where the 

structure falls on and injures an 

animal during the inspection.

Structural deterioration, such as 

rusted support posts, where the 

structure had fallen on the dogs and 

caused injury or death.

Facilities not maintained; 

animals escape and are 

returned unharmed.

Facilities not maintained; during 

the inspection animals escaped 

and were severely injured or 

died.

Prior to the inspection, facilities not 

maintained; animals escaped and 

were not returned or were severely 

injured or died. 

Live electric wire exposed 

to and within easy reach of 

dogs (insulation removed, 

and/or bare ends of cord 

exposed).

Live electric wire exposed to and 

within easy reach of dogs 

(insulation removed, and/or bare 

ends of cord exposed) and during 

the inspection one or more 

animals experienced a serious 

burn, or other serious injury.

Live electric wire exposed to and 

within easy reach of dogs (insulation 

removed, and/or bare ends of cord 

exposed) and animal experienced a 

severe burn, other serious injury, or 

died as a result. 
--- Animal Care Inspection Guide ---

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Regulation NCI Direct Critical

Section 3.1(b)

Housing 

Facilities, 

General: 

Condition and 

site

Clutter making it difficult 

or impossible to 

clean/sanitize or evidence 

of rodent/vermin 

infestation.

Gross contamination found in 

dog food bowls, mixed with feed, 

resulting in one or more dogs 

showing serious, related clinical 

signs, such as vomiting or 

diarrhea during the inspection. 

Prior to the inspection, gross 

contamination found in dog food 

bowls, mixed with feed, resulted in 

one or more dogs showing serious, 

related clinical signs, such as 

vomiting or diarrhea.

Sections 3.2(a), 3.3(a), 3.5(a)

Indoor 

Housing 

Facilities, 

Sheltered; or

Housing 

Facilities; 

Mobile; or 

Traveling 

Housing 

Facilities

Temp marginally below/ 

above allowable range 

(between 35-45°F or 

slightly above 85°F), 

animals not showing signs 

of distress.

Temperature outside of 

allowable ranges, animal showing 

signs of distress during the 

inspection.

.

Prior to the inspection, temperature 

was outside of allowable ranges, 

animal died or was severely affected 

as a result.

Sections 3.2(b), 3.3(b), 3.5(b)

Indoor 

Housing 

Facilities; or 

Sheltered 

Housing 

Facilities; or 

Mobile or 

Traveling 

Housing 

Facilities

Lack of ventilation without 

noxious fumes; animals 

may show sign(s) of 

discomfort.

Lack of ventilation to the point 

where there are noxious fumes 

(e.g., your eyes burn) at the level 

of the animal’s eyes and nose; 

dogs are showing signs of 

discomfort and/or distress, such 

as squinting, coughing, sneezing, 

nasal discharge, etc.

Sections 3.2(c), 3.3(c), 3.5(c)

Indoor 

Housing 

Facilities, 

Sheltered 

Housing 

Facilities, 

Mobile or 

Traveling 

Housing 

Facilities

Absence of lighting and/or 

absence of diurnal cycle 

(no windows and no

broad-spectrum lighting 

with appropriate cycling of 

light and dark).

Absence of lighting and/or 

absence of diurnal cycle (no 

windows and no broad-spectrum 

lighting with appropriate cycling 

of light and dark) and signs of 

stress, distress, or poor health 

are evident.

Lighting is not sufficient to 

maintain good 

housekeeping and cleaning 

(dark areas have 

accumulation of dirt) and 

adequate inspection 

cannot be performed in all 

areas.

There are no apparent 

health impacts on the 

animal(s).
--- Animal Care Inspection Guide ---

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Regulation NCI Direct Critical

Sections 3.3(d), 3.4(b)

Sheltered 

Housing 

Facilities, 

Outdoor 

Housing 

Facilities,

Shelter from 

the elements

Sheltered area not large 

enough for all dogs/cats to 

sit, stand lie in a normal 

manner, and to turn about 

freely and temp over 50°F. 

Animals are not showing 

severe signs of distress. 

Sheltered area not large enough 

for all dogs to sit, stand, lie in a 

normal manner, and to turn 

about freely, and temperature 

under 50°F or over 85 °F; dogs 

showing signs of discomfort 

and/or distress, such as heavy 

panting, or shivering. 

Section 3.4(a)

Outdoor 

Housing 

Facilities

Dogs and cats maintained 

in areas to which they are 

not acclimated to the 

temperatures prevalent in 

the areas. Animals are not 

showing severe signs of 

distress.

Dogs and cats maintained in 

areas to which they are not 

acclimated to the temperatures 

prevalent in the area, and/or 

breeds of dogs and cats 

maintained in areas in which they 

cannot tolerate the prevalent 

temperatures without stress with 

veterinary care issues. Animals 

are showing severe signs of 

distress.

Section 3.4(b)

Outdoor 

Housing 

Facilities

Shelter with no bedding 

and temp between 35 and 

50°F, no signs of 

discomfort.

Shelter without sufficient 

bedding and temperature under 

35 °F, or between 35 and 50 °F 

with dogs showing signs of 

discomfort (shivering).

Shelter structure is not 

large enough for all 

dogs/cats to sit, stand lie 

in a normal manner, to 

turn about freely, or has 

Insufficient wind/ rain 

break. High winds and/or 

precipitation are not 

present. 

Shelter structure is not large 

enough for all dog/cats to sit, 

stand lie in a normal manner, to 

turn about freely, or insufficient 

wind/ rain break and 

temperature under 50 °F, and/or 

high winds and/or precipitation 

are present. Animals are 

showing signs of distress. 

Water in shelter with wet dogs. 

Section 3.6(a)(2)(v)

Primary 

Enclosure

Enclosure not constructed 

and maintained to protect 

the dogs from injury, 

safely contain the dogs, 

keep other animals from 

entering the enclosure, 

enable dogs to remain dry, 

etc. Little or no 

discernable impacts on the 

dogs is noted.

Enclosure not constructed and 

maintained as required, resulting 

in signs of distress, injury, illness, 

or death seen at the time of the 

inspection.

Enclosure were not constructed and 

maintained as required, resulting in 

signs of distress, injury, illness, or 

death occurring prior to the 

inspection.

Section 3.6(c)(1)

Primary 

Enclosure, 

Space

Enclosure does not meet 

minimum floor space 

requirements and no 

behavioral issues.

Enclosure does not meet 

minimum floor space 

requirements and dog has 

behavioral and/or medical issues 

seen at the time of the 

inspection. (Example: lick 

granuloma).
--- Animal Care Inspection Guide ---

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Regulation NCI Direct Critical

Section 3.7

Compatible 

Grouping

One or more dogs does 

not let other dog(s) eat. 

The dog who is unable to 

access food is in good 

flesh.

Incompatible dogs housed 

together with injuries and/or 

signs of distress seen at the time 

of the inspection.

One or more dogs does not let 

other dog(s) eat. The dog who is 

unable to access food has signs of 

distress and/or emaciation. 

Prior to the inspection, incompatible 

dogs were housed together, resulting 

in serious injury or death to one or 

more of the dogs. 

Section 3.8

Exercise Not seeking or following 

the specific guidance 

provided by the Attending 

Veterinarian for the 

exercise of their dogs. 

Dogs appear normal. 

Insufficient floor space and no 

opportunity for exercise (no 

written plan, no evidence of 

exercise area).

During the inspection, dogs are 

showing serious clinical signs 

related to the lack of opportunity 

to exercise.

Section 3.9(a)

Feeding Food contaminated with 

feces, urine, mold, mildew, 

pest waste. Dogs not 

showing related clinical 

signs.

Food contaminated with feces, 

urine, mold, mildew, pest waste 

to an extent that it is rendered 

unpalatable and/or harmful to 

the animals. Dogs are showing 

clinical signs such as vomiting, 

diarrhea, or emaciation during 

the inspection.

Emaciated dogs with no feed 

present or inappropriate feed.

Section 3.10(a)

Watering Dogs do not have 

continuous access to 

potable water. 

Dogs do not have continuous 

access to potable water, and 

when offered water, drink 

voraciously and/ or in a manner 

that demonstrates they are 

extremely thirsty.

Water contaminated with feces, 

urine, pest waste, and mud to an 

extent that it is rendered 

unpalatable and/or harmful to 

the animals.

Section 3.11(d)

Pest Control Infestation with some 

control in place and no 

obvious contamination of 

feed, water.

Vermin are seen in the dog pens, 

eating/defecating and/or getting 

into the food supply. Dogs are 

showing clinical signs related to 

the vermin.

Section 3.12

Employees Multiple non-critical NCIs 

noted on the inspection 

report attributable to lack 

of employees.

The lack of an adequate number 

of employees, resulting in a 

failure to take immediate and 

appropriate action for dogs that 

are injured or ill.
--- Animal Care Inspection Guide ---

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Regulation NCI Direct Critical

Sections 3.14(a)(b)(c)

Consignments 

to Carriers and 

IH

Animal is accepted more 

than 4 hrs. prior to 

departure, animal has not 

received attention, does 

not appear ill or in distress. 

A carrier/IH accepts an animal 

more than 4 hour before the 

scheduled flight departure, and 

there was no documentation as 

to when the animal was last fed 

or watered; and the animal either 

voraciously goes for food/water 

when offered, or it becomes ill 

and needs vet attention, or dies.

Section 3.14(d)

Consignments 

to Carriers and 

IH

Animal breaks out of 

transport enclosure and is 

quickly recaptured without 

any injuries.

Carrier/IH accepts dog for 

transport in an inadequate 

primary enclosure; during the 

inspection, dog breaks out of the 

transport enclosure and is lost, 

injured, or killed.

Prior to the inspection, Carrier/IH 

accepted dog for transport in an 

inadequate primary enclosure; dog 

broke out of the transport enclosure 

and was lost, injured, or killed.

Section 3.14(e)

Animal 

Holding Area

Temperature falls below 

45°F for more than 45 

mins but the animals 

appear fine.

Temperature falls below 45°F for 

more than 45 mins and during 

the inspection, the animal is 

noted as being distressed.

Prior to the inspection, temperature 

in holding area was too low and 

animal was distressed or died from 

the exposure.

Section 3.14(f)

Consignments 

to Carriers and 

IH

No documentation was 

made that the consignee 

was notified when the 

shipment arrived nor every 

6 hours thereafter. No 

apparent effect on the 

animals.

No documentation was made that 

the consignee was notified when the 

shipment arrived, nor every 6 hours 

thereafter. The animal died due to 

the delay in notifying the consignee. 

Section 3.15(a)

Primary 

Enclosure 

Used 

to Transport 

Live Dogs and 

Cats

Animal was able to escape 

the transport enclosure 

but was quickly recaptured 

without injury. 

Limbs protruding from the 

enclosure.

Not enough ventilation 

openings on the enclosure. 

No related clinical signs 

seen.

Live animal labels and/ or 

arrows missing, a few 

broken wire welds, no 

handles noted, but not 

affecting animals’ health/ 

comfort.

During the inspection:

- Animal was able to escape the 

transport enclosure resulting in 

injury, distress, or death.

- Limbs protruding from the 

enclosure resulting in injury, 

distress, or death.

- Not enough ventilation 

openings on the enclosure 

resulting in injury, distress, or 

death.

- Emergency presented itself and 

the animal enclosure could not 

be moved in a timely manner 

resulting in injury, distress, or 

death.

Prior to the inspection:

- Animal was able to escape the 

transport enclosure resulting in 

injury, distress, or death.

- Limbs protruding from the 

enclosure resulting in injury, distress, 

or death.

- Not enough ventilation openings on 

the enclosure resulting in injury, 

distress, or death.

- Emergency presented itself and the 

animal enclosure could not be 

moved in a timely manner resulting 

in injury, distress, or death.

Section 3.15(b)

Cleaning of 

primary 

enclosures 

(transport)

Animal was not removed 

from crate after 24 hours 

in transport status, but 

there was enough 

absorptive material 

present to absorb the 

urine and cover the feces.

During the inspection, the animal 

is seen covered in feces/urine 

because it has been in transport 

crate more than 24 hrs. 

Prior to the inspection, the animal 

was covered in feces/urine because 

it had been in transport crate more 

than 24 hrs. 
--- Animal Care Inspection Guide ---

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Regulation NCI Direct Critical

Section 3.15(c)

Primary 

Enclosure 

Used to 

Transport Live 

Dogs and Cats 

- Ventilation

The transport crate does 

not meet the % 

requirements but the 

animal appears fine.

The transport enclosure does not 

meet the ventilation 

requirements. 16%/14%/50% 

etc., and during the inspection, 

the animal shows significant signs 

of distress, or is seriously harmed 

or dies.

The transport enclosure did not meet 

the ventilation requirements – 16%/14%/50% etc., and prior to the 

inspection, the animal was seriously 

harmed or died.

Section 3.15(d)

Primary 

Enclosure 

Used to 

Transport Live 

Dogs and Cats 

- Compatibility

A small puppy is shipped 

with a larger puppy (i.e. 5 

lb. and 15 lb.) but they 

appear well.

A large puppy or dog is put into a 

transport enclosure with a small 

puppy or dog, and the smaller 

dog is seriously injured or dies 

during the inspection.

Prior to the inspections, a large 

puppy or dog was put into a 

transport enclosure with a small 

puppy or dog, and the smaller dog 

was seriously injured or killed.

An overly aggressive dog was 

shipped with another dog and the 

submissive dog was seriously injured 

or killed.

Section 3.16(a-h)

Primary 

Conveyances

Primary conveyance is 

structurally unsound— exhaust fumes enter the 

cargo space and/or air 

flow is hindered, and/or 

animals are exposed to too 

cold or too hot 

temperatures, and/or dry 

ice is in the cargo space, 

etc.; there were no 

apparent health impacts to 

the animals.

Primary conveyance is 

structurally unsound—exhaust 

fumes enter the cargo space 

and/or air flow is hindered, 

and/or animals are exposed to 

too cold or too hot temperatures, 

and/or dry ice is in the cargo 

space, etc. The result is injury, 

distress, or death during the 

inspection. 

Primary conveyance was structurally 

unsound—exhaust fumes entered 

the cargo space and/or air flow was 

hindered, and/or animals were 

exposed to too cold or too hot 

temperatures, and/or dry ice was in 

the cargo space, etc. The result was 

injury, distress, or death prior to the 

inspection.

Section 3.17

Food and 

Water 

Requirements

Animals less than 16 

weeks of age being 

transported for more than 

12 hrs. and are not fed or 

offered water, but there 

are no apparent health 

impacts on the animals.

Animals are transported for more 

than 12 hours and are not fed or 

offered water (if under 16 

weeks), and during the 

inspection, animals are noted to 

be in distress and/or dehydrated 

and/or needing veterinary care 

and/or die.

Prior to the inspection, animals were 

transported for more than 12 hours 

and were not fed or offered water (if 

under 16 weeks), resulting in distress 

and/or dehydration, and/or needing 

veterinary care, and/or died.

Animals over 16 weeks of 

age are not offered food at 

least every 24 hours, but 

there is no apparent 

health effect on the 

animal.

Animals over 16 weeks of age are 

not offered food at least every 24 

hours and during the inspection, 

animals are noted to be in 

distress, or need vet care.

Prior to the inspection, animals over 

16 weeks of age were not offered 

food at least every 24 hours resulting 

in distress or death.

Potable water is not 

offered at least every 12 

hours, but there is no 

apparent health effect on 

the animal.

Potable water is not offered at 

least every 12 hours and at the 

time of the inspection, the animal 

is in distress, dehydrated or 

needs vet care.

Potable water was not offered to the 

animals at least every 12 hours 

resulting in distress or death. 
--- Animal Care Inspection Guide ---

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Regulation NCI Direct Critical

Section 3.18(a)

Care in Transit 

- Surface 

Transit

Animals are not observed 

every 4 hours, but no 

animal becomes severely 

ill or dies.

Animals are either in a truck or in 

a plane and are not observed 

every 4 hours (if applicable), and 

during the inspection, the 

animals become severely ill, 

injured, distressed, and/or die.

Animals were either in a truck or in a 

plane and were not observed every 4 

hours (if applicable), and prior to the 

inspection, the animals became 

severely ill, injured, distressed, 

and/or died.

Section 3.18(b)

Care in Transit 

- Air Transit

During the inspection, an animal 

was in obvious physical distress, 

and veterinary care was not 

arranged as soon as possible.

Prior to the inspection, an animal 

was in obvious physical distress and 

veterinary care was not arranged as 

soon as possible.

Section 3.18(c)

Care in Transit Animal was obviously ill, injured, or 

in obvious physical distress, but was 

transported anyway.

Section 3.18(d)

Care in Transit Animal was removed from the 

transport enclosure resulting in 

severe adverse effects, escape and 

failure to recover, and/or death.

Section 3.19(a)

Terminal 

Facilities - 

Placement

Animal crates are housed 

next to inanimate cargo, 

but animals are not 

injured.

During the inspection, animal 

crates are housed next to 

inanimate cargo/boxes; the 

boxes fall and damage the 

crate(s) causing harm to the 

animal(s).

Prior to the inspection, animal crates 

were housed next to inanimate 

cargo/ boxes; the boxes fell and 

damaged the crate(s) causing harm 

to the animal(s).

Section 3.19(c)

Terminal 

Facilities - Ventilation

Lack of ventilation to the point 

where there are noxious fumes 

(e.g., your eyes burn) at the level 

of the animal’s eyes and nose; 

dogs are showing signs of 

discomfort and/or distress.

Section 3.19(d)

Terminal 

Facilities - Temperature

Temperatures allowed to 

fall below 45°F or rise 

above 85°F but animals 

appear well with no 

apparent health effects.

At the time of the inspection, 

temperatures are allowed to fall 

below 45°F or rise above 85°F, 

which results in the animals 

showing signs of discomfort, 

distress, or death.

Prior to the inspection, temperatures 

were allowed to fall below 45°F or 

rise above 85°F, which results in the 

animals showing signs of discomfort, 

distress, or death.

Section 3.19(e)

Terminal 

Facilities -

Shelter

Animals are exposed to 

extreme elements (i.e. 

rain/snow/wind/ice/etc.), 

but animals appear well 

with no apparent health 

effects.

During the inspection, animals 

are not provided shelter to 

extreme elements, which results 

in the animals being injured, or 

showing signs of discomfort, 

distress, or death.

Prior to the inspection, animals were 

not provided shelter to extreme 

elements, which resulted in animal 

injury or death.
--- Animal Care Inspection Guide ---

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Regulation NCI Direct Critical

Section 3.20(a)

Handling Animals are exposed to 

the elements but appear 

well with no apparent 

health effects.

When moving animals from the 

terminal facility to plane side, the 

animals were exposed to 

prolonged time out in the sun, 

extreme heat, rain, snow, or 

extreme cold, and now (during 

the inspection) show signs of 

injury, discomfort, distress, or 

death.

Prior to the inspection, when moving 

animals from the terminal facility to 

plane side, the animals were exposed 

to prolonged time out in the sun, 

extreme heat, rain, snow, or extreme 

cold, resulting in injury, discomfort, 

distress, or death.

Section 3.20(b)

Handling Crate is inappropriately 

placed on conveyor belt 

but is handled safely and 

animal appears well with 

no apparent health 

impacts.

During the inspection, a transport 

enclosure is put on an 

unattended conveyor belt or is 

haphazardly put onto an 

unattended belt and the 

enclosure falls off and the animal 

is distressed and or injured.

Prior to the inspection, a transport 

enclosure was put on an unattended 

conveyor belt or was haphazardly 

put onto an unattended belt and the 

enclosure fell off resulting in distress, 

injury, or death. 

Examples for Other Animals 

Section 2.40 - Attending Veterinarian and Adequate Veterinary Care

The Veterinary Care Flow Chart should be followed for all applicable decisions regarding veterinary 

care citations. The main purpose of this chart is to assist the inspector in distinguishing between a noncritical, Direct, or Critical NCI. 

If a licensee or registrant can demonstrate via records or other means that he/she has taken the 

proper steps to mitigate the injury and/or death of the animal, a noncompliance has not occurred:

• These proper steps include, but are not limited to:

o Identifying the condition requiring veterinary care in a timely manner,

o Acquiring veterinary care and/or initiating treatment in a timely manner, 

and/or

o Following the treatment instructions of the Attending Veterinarian

Regulation NCI Direct Critical

2.40 All 

Sections

Noncompliance with any 

section of the veterinary 

care regulations in which 

there are no known (or 

minor) resulting impacts 

to the health and wellbeing of the animals. The 

noncompliance does not 

meet the definition of a 

teachable moment. 

At the time of the inspection, 

noncompliance with any section of 

the veterinary care regulations 

that results in serious health 

impacts (including lack of 

treatment for a serious condition) 

or death to one or more animals.

Prior to the inspection, 

noncompliance with any section of 

the veterinary care regulations that 

results in serious health impacts 

(including lack of treatment for a 

serious condition) or death to one or 

more animals

2.40(b)(1,2,4) - Nondomestic 

cats 4 weeks 

or younger –

transport, 

exhibition, 

public 

handling 

At the time of the inspection, the 

inspector observes serious 

negative impacts to the animal.

The animal was transported, 

exhibited, or handled by the public. 
--- Animal Care Inspection Guide ---

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Regulation NCI Direct Critical

Section 2.131 – Handling of Animals

Section 2.131 

and all 

subsections

Noncompliance with any 

section of the handling 

regulations in which 

there are no known (or 

minor) resulting impacts 

or risks to the animals or 

the public. The 

noncompliance does not 

meet the definition of a 

teachable moment. 

At the time of the inspection, 

noncompliance with any section of 

the handling regulations that 

results in serious injury or health 

impacts, or death to one or more 

animals or one or more members 

of the public. 

Prior to the inspection, 

noncompliance with any section of 

the handling regulations that results 

in serious injury or health impacts, or 

death to one or more animals or one 

or more members of the public. 

2.131(b)(1), 

(c)(1), (c)(3), 

(d)(1), (e) -

Nondomestic 

cats 4 weeks 

or younger –

transport, 

exhibition, 

public 

handling 

At the time of the inspection, the 

inspector observes serious 

negative impacts to the animal.

The animal was transported, 

exhibited, or handled by the public. 

Section 3 – Standards for Subpart F Animals

Section 3.125 - Facilities, general

(b) Water and 

Power

No potable water 

present, or non-potable 

stagnant water present.

Impacts to the animal(s) 

are minor or not 

observed. 

No potable water present and 

signs observed during the 

inspection of dehydration or other 

illness directly attributable to lack 

of potable water.

Animal died prior to inspection due 

to dehydration associated with nonpotable water.

(c) Storage Supplies of food and 

bedding are mildly 

deteriorated/moldy/

contaminated due to 

facility issues, with no 

known animal welfare 

impacts.

Animal illness directly attributable 

to food and bedding which are 

deteriorated/moldy/contaminated.

Animal death prior to inspection 

directly attributable to supplies of 

food and bedding that are 

deteriorated/molded/contaminated.

(d) Waste 

Disposal

Inappropriate or 

inadequate removal of 

food wastes, bedding, 

dead animals, trash and 

debris in some areas of 

the primary enclosure. 

Inappropriate or inadequate 

removal of food wastes, bedding, 

dead animals, trash and debris in

some areas of the primary 

enclosure resulting in serious 

illness or injury observed at the 

time of the inspection.

(a) Structural 

Strength 

Fencing that is damaged 

or rusted and is affecting 

the strength of the 

materials.

Screw that has come 

loose from a board which 

protrudes into the 

enclosure and could 

cause injury to the 

animal.

Does not meet the 

definition of a teachable 

moment.

Animal trapped or entangled by 

fencing at the time of the 

inspection.

Animal is seriously injured or killed 

at the time of the inspection due 

to noncompliance with this 

section. 

Animal died or was seriously injured 

prior to the inspection due to fence 

entrapment or other noncompliance 

with this section.

Necropsy report specifically indicates 

that animal died due to injury caused 

by screw protruding from board prior 

to inspection.
--- Animal Care Inspection Guide ---

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Regulation NCI Direct Critical

Section 3.126 - Facilities, Indoor

(a) Ambient 

temperatures

High or low temperatures 

that are not compatible 

with the health and 

comfort of the animal. 

Impacts to the animal(s) 

are minor or not 

observed. 

Animal illness or significant impact 

directly attributable to extreme 

temperature at the time of the 

inspection

Animal death prior to inspection 

directly attributable to facility issues 

of extreme temperature.

(b) Ventilation Poor ventilation that is 

not compatible with the 

health and comfort of the 

animal. .Impacts to the 

animal(s) are minor or 

not observed. 

Animal illness or significant 

impacts directly attributable to 

poor ventilation at the time of the 

inspection.

Animal death prior to inspection 

directly attributable to poor 

ventilation.

(c) Lighting Poor lighting or 

inappropriate lighting for 

the species involved.

Lighting that does not 

permit routine inspection 

and cleaning.

Animal illness or significant impact 

observed during the inspection 

that is directly attributable to 

inadequate lighting.

Animal death prior to inspection 

directly attributable to inadequate 

lighting.

(d) Drainage Inability to rapidly 

eliminate excess water 

from indoor housing.

Backup of sewage or 

significant foul odors 

caused by drainage that is 

in disrepair.

Impacts to the animal(s) 

are minor or not 

observed. 

At the time of the inspection, 

animal illness or significant impacts 

directly attributable to inadequate 

drainage.

Animal death or significant impact to 

animal health and/or welfare prior to 

inspection directly attributable to 

inadequate drainage.

3.127 - Facilities, Outdoor

(b) Shelter 

from 

inclement 

weather

Insufficient shelter to 

protect the animals from 

discomfort caused by 

local climatic conditions. 

Impacts to the animal(s) 

are minor or not 

observed. 

Significant animal impacts 

(frostbite etc...) are observed due 

to insufficient shelter to protect 

the animals from discomfort 

caused by local climatic conditions 

at the time of the inspection.

Severe injury or animal death prior 

to inspection directly attributable to 

failure to provide shelter from local 

climatic conditions. 

(c) Drainage Inability to rapidly 

eliminate excess water.

Moderately sized areas of 

standing water/mud. 

Animals may be forced to 

walk through mud/water 

to access food or clean 

water, but there are 

areas in which the 

animals can stand, sit, or 

move around and remain 

out of the water

At the time of inspection, animal 

illness or significant impact directly 

attributable to drainage.

Areas of standing water/mud that 

animals refuse (or show signs of 

distress) to walk through 

mud/water to access food or clean 

water. There are no areas in the 

enclosure in which the animals can 

be stand, sit, or move around in 

without being in the water/mud. 

Animal injury, illness, or death prior 

to inspection directly attributable to 

inadequate drainage.
--- Animal Care Inspection Guide ---

Savedate 12/7/2021 9:38 AM NCI/Direct/Critical Noncompliance Examples C-16

Regulation NCI Direct Critical

(d) Perimeter 

Fence

Fence that is not of 

sufficient height to keep 

animals and authorized 

persons out.

Fences less than 8 feet 

high for potentially 

dangerous animals.

Perimeter fences less 

than 6 feet high for nondangerous animals.

Perimeter fences less 

than 3 feet from primary 

enclosure.

No known impacts to 

covered animals.

Prior to the inspection, animal injury, 

disease, or death directly due 

perimeter fence noncompliance. 

Section 3.128

Space 

Requirements

Animal housed in a small 

enclosure that does not 

allow for normal freedom 

of movement. 

Impacts to the animal(s) 

are minor or not 

observed. 

Wallabies are being kept 

in a vari-kennel each 

night which does not 

allow them to stand 

upright or move freely. . Impacts to the animal(s) 

are minor or not 

observed

At the time of the inspection:

Animal housed in a small, bare 

enclosure and is exhibiting signs of 

distress, poor body condition, or 

other serious health impacts 

Insufficient space that is indicated 

by evidence of malnutrition, poor 

conditions, debility, severe stress,

or abnormal behavior patterns that 

are causing the animal to exhibit 

signs of pain or discomfort.

Wallabies are being housed in varikennels that do not allow them to 

stand. They have pressure sores 

on their hocks, hair loss on their 

heads and tails, and poor body 

condition.

Insufficient space that is indicated by 

evidence of malnutrition, poor 

conditions, debility, stress, or 

abnormal behavior patterns that 

directly contributed to an animal’s 

death prior to inspection.
--- Animal Care Inspection Guide ---

Savedate 12/7/2021 9:38 AM NCI/Direct/Critical Noncompliance Examples C-17

Regulation NCI Direct Critical

Section 3.129

Feeding Food that is deemed to 

not be wholesome, 

palatable, of a sufficient 

quantity and nutritive 

value that allows the 

animals to maintain 

normal body conditions 

based on species

Food that is not 

prepared, stored, or 

maintained in a way that 

would avoid 

contamination (food or 

food receptacles with 

molding, deterioration, 

caking of food, etc.)

Insufficient number of 

feeders or feeding 

locations that are 

accessible to all animals 

within the enclosure 

Meat that is being 

thawed outside of 

refrigerator or other 

controlled temperature. 

No immediate impact to 

the animal(s) was noted.

Only frozen meat is fed to 

the animals, no impact 

observed at the time of 

the inspection.

For the examples above, 

impacts to the animal(s) 

are minor or not 

observed. 

At the time of the inspection, 

animal illness or significant impact 

directly attributable to improper 

feeding or food storage. 

Rotten or frozen meat supplied to 

animals, animal refusal or signs of 

nutritional deficiencies noted 

during inspection.

Animal death prior to inspection that 

was directly attributable to improper 

feeding or food storage.

Section 3.130

Watering Stagnant pond or puddle 

as only source of drinking 

water (may see algae 

growth or waste material 

accumulating at surface). 

Running water (stream, 

creek, river, etc.) will be 

assumed potable unless 

reason to believe 

otherwise.

An insufficient quantity of 

potable water being 

provided based on local 

climate conditions. 

Improper cleaning and 

sanitations of water 

receptacles with evidence 

of significant animal 

waste, algal buildup, or 

insect larvae present.

Animal illness or significant impact 

directly attributable to improper 

cleaning of water container or lack 

of potable water. (signs of severe 

dehydration, loose stool, etc.)

NOTE: Water potability testing is 

not a requirement.

Animal death prior to inspection that 

was directly attributable to improper 

cleaning of water receptacles or lack 

of potable water.

NOTE: Water potability testing is not 

a requirement.
--- Animal Care Inspection Guide ---

Savedate 12/7/2021 9:38 AM NCI/Direct/Critical Noncompliance Examples C-18

Regulation NCI Direct Critical

Section 3.131 - Sanitation

(a) Cleaning of 

enclosures 

Improper removal of 

excreta or food wastes 

from enclosures that do 

not allow the animals to 

avoid contamination. 

Impacts to the animal(s) 

are minor or not 

observed. 

At the time of the inspection, 

animal illness or significant impact 

directly attributable to improper 

removal of excreta or food wastes 

from the enclosure.

There are no areas in the enclosure 

in which the animal can stand, sit, 

or move in without being in 

excreta.

Animal death prior to inspection that 

resulted from an illness or significant 

impact that was directly attributable 

to improper removal of excreta or 

food wastes from the enclosure.

(b) Sanitation 

of enclosures

Improper cleaning of 

cages, rooms, and hard- surfaced pens or runs 

after containing an 

animal with an infectious 

or transmittable disease.

At the time of the inspection, one 

or more animals showing signs of a 

significant impact that was directly 

attributable to the improper 

cleaning of cages, rooms, and 

hard-surfaced pens or runs that 

had previously housed an animal 

known to have had an infectious or 

transmittable disease.

Disease outbreaks/spreading as a 

direct attributable to improper 

cleaning.

(d) Pest 

Control

Unsafe pest control 

methods for the species 

being used (poison or 

other pest control 

methods being used in 

areas that are accessible 

to the animals or within 

the animals reach that 

could cause illness or 

injury). Impacts to the 

animal(s) are minor or 

not observed. 

Ineffective pest control 

methods being used (pest 

control methods in place 

that are not working or is 

not sufficient enough to 

maintain pests at an 

acceptable level). Impacts 

to the animal(s) are 

minor or not observed. 

At the time of the inspection, 

animal illness or significant impacts 

directly attributable to coming in 

contact with or ingesting the pest 

control methods that are in place 

at the facility.

At the time of the inspection, 

animal illness or significant impacts 

that is directly attributable to the 

presence of pests or pest control 

methods at the facility.

Prior to the inspection, animal death 

illness that is directly attributable to 

pests or pest control methods at the 

facility.

Section 3.132

Employees Buildup of manure in a 

hoof stock barn, , the 

presence of one or more 

carcasses in big cat 

enclosure or the lack of 

bedding changes leading 

to buildup of feces and 

urine-soaked bedding 

material in a small 

mammal enclosure due 

to insufficient number of 

adequately trained 

employees used to 

maintain the husbandry 

of the animals. Impacts to 

the animal(s) are minor 

or not observed. 

At the time of the inspection, 

animal illness or significant impact 

directly attributable to insufficient 

number of adequately trained 

employees used to maintain the 

husbandry of the animals.

Animal death prior to inspection 

directly attributable to insufficient 

number of adequately trained 

employees used to maintain the 

husbandry of the animals.
--- Animal Care Inspection Guide ---

Savedate 12/7/2021 9:38 AM NCI/Direct/Critical Noncompliance Examples C-19

Regulation NCI Direct Critical

Section 3.133 - Separation

Species 

Example: 

Exotic hoof 

stock 

Dominant male 

preventing others from 

gaining access to food or 

water. No significant 

animal illness or 

significant impact but the 

facility has failed to 

provide alternative 

sources of food or water 

to the others in the 

enclosure.

At the time of the inspection, 

incompatible animals housed in 

the same enclosure that has 

caused significant animal illness or 

significant impact. The facility has 

not yet separated the animals or 

made previsions to prevent 

reoccurrence.

At the time of the inspection, zebra 

stallion housed with foals that has 

caused significant injury to one or 

more foals and the facility has not 

separated the animals to prevent 

reoccurrence. 

Adult male rhino that has gored and 

killed a giraffe prior to inspection.

Species 

Example: Big 

Cat

At the time of the inspection, fight 

between big cats that has caused 

significant animal illness or 

significant impact. The facility has 

not yet separated the animals or 

made previsions to prevent 

reoccurrence.

Animal death or serious injury 

caused by a fight between big cats 

prior to inspection and is directly 

attributable to incompatibility. 

Species 

Example: 

Small 

exotic/wild 

mammal

At the time of the inspection, adult 

male housed with young offspring 

that has caused significant injury to 

one or more animals.

Adult male housed with young 

offspring that has caused death or 

significant injury to one or more 

animals prior to the inspection. 

Species 

Example: 

Small 

exotic/wild 

mammal

Two bettongs housed in a 

wire enclosure adjacent 

to a fox enclosure. The 

bettongs are not eating 

much and constantly 

hide.

At the time of the inspection, two 

bettongs are housed in a wire 

enclosure. One of them guards the 

food and will not allow the other 

one to eat. The other bettong is 

very thin and has a scab on its ear.

Prior to the inspection, a female 

bettong previously injured the male 

that it is housed with. The facility 

kept them together and female 

injured the male again, resulting in a 

partial foot amputation.
--- Animal Care Inspection Guide ---

Savedate 12/7/2021 9:38 AM Equipment and Supplies D-1

Equipment and Supplies

Equipment

The following equipment is required:

• Camera/video camera, memory card, and extra batteries

• Cellular phone

• First-aid kit

• Laptop computer

• Official identification (badge and LincPass)

• Printer and paper

• MiFi / Jetpack

The following equipment is highly recommended:

• Blank Inspection Report forms (in case of computer/printer failure)

• Business cards

• Coveralls, preferably disposable

• Disposable boots

• Extra printer cartridge

• Flashlight and extra batteries

• GPS and/or maps

• Hearing Protection

• Kestrel Weather Meter

• Note pad

• Pen/pencil

• Raytek MiniTemp Thermometer

• Reference material, such as:

o Subpart A – Animal Welfare

o Inspection Guide

o Reference texts

• Soap/disinfectant/hand sanitizer

• Tape measure

The following items are optional:

• Binoculars

• Calculator

• Hand counter

• Inspection checklists

• Towels/paper towels
--- Animal Care Inspection Guide ---

Savedate 12/7/2021 9:38 AM Equipment and Supplies D-2

Special Equipment

Nonhuman Primates

The following equipment is recommended for inspecting facilities with macaques, if within 5 

feet of the macaques:

• Biological waste bag

• Coveralls – preferably disposable

• Disinfectant

• Disposable gloves

• Monkey Bite/Scratch Kit

• Full face shield and eye protection, such as safety glasses or goggles

• Respirator

The following equipment is recommended for inspecting facilities with other nonhuman 

primates:

• Respirator – Level N95, or better

Other Animals

The following equipment is recommended for inspecting elephants:

• Respirator – Level N95, or better

Supplies

The following forms and information should be available for distribution to the facility and general 

public by the inspector:

• The Animal Welfare Act

• AWA Regulations and Standards (Blue Book)

• APHIS Fact Sheets and Tech Notes

• APHIS Forms for record keeping:

o APHIS Form 7002–Program of Veterinary Care

o APHIS Form 7005–Record of Acquisition of Dogs and Cats on Hand

o APHIS Form 7006–Record of Disposition of Dogs and Cats

o APHIS Form 7006A–Continuation Sheet for Record of Disposition of Dogs 

and Cats

o APHIS Form 7019–Record of Animals on Hand (Other than Dogs and Cats)

o APHIS Form 7020–Record of Acquisition, Disposition or Transport of 

Animals (Other Than Dogs and Cats)

NOTICE

To wear a respirator, you must meet the APHIS Respirator Program 

requirements, i.e., medical clearance and fit testing.
--- Animal Care Inspection Guide ---

Savedate 12/7/2021 9:38 AM Equipment and Supplies D-3

o APHIS Form 7020A-Continuation Sheet for Record of Acquisition, 

Disposition, or Transport of Animals (Other than Dogs and Cats)

o Options for Identification of Dogs and Cats
--- Animal Care Inspection Guide ---

Savedate 12/7/2021 9:38 AM Body Condition and Size Charts E-1

Body Condition and Size Charts

Contents

Cat E-2

Cougar E-3

Dog E-4

Elephant E-5

Leopard E-6

Lion E-7

Tiger E-8

Tiger cub size information E-9

These charts may be used to help inspectors identify animals in critical or near 

critical condition which, if not addressed, could trigger a confiscation.
--- Animal Care Inspection Guide ---

Savedate 12/7/2021 9:38 AM Body Condition and Size Charts E-2

Cat

Emaciated Ribs, lumbar vertebrae, pelvic bones and all body 

prominences evident from a distance. No 

discernible body fat. Obvious absence of muscle 

mass.

Underweight Ribs easily palpated and may be visible with no 

palpable fat. Tops of lumbar vertebrae visible. 

Pelvic bones less prominent. Obvious waist and 

abdominal tuck.

Optimal body weight Ribs palpable without excess fat covering. 

Abdomen tucked up when viewed from side.

Overweight General fleshy appearance. Ribs palpable with 

difficulty. Noticeable fat deposits over lumbar 

spine and tail base. Abdominal tuck may be 

absent.

Obese Large fat deposits over chest, spine, and tail base. 

Fat deposits on neck and limbs. Abdomen 

distended.

Source: Ohio State University, College of 

Veterinary Medicine
--- Animal Care Inspection Guide ---

Savedate 12/7/2021 9:38 AM Body Condition and Size Charts E-3

Cougar

Emaciated No photo All ribs and vertebral bodies prominently 

showing, skin laying over hips and femur

Underweight Ribs, vertebral bodies and hips slightly showing, 

“tucked up” appearance

Optimal body weight Hint of ribs and vertebral bodies

(https://commons.wikimedia.org/wiki/File%3AM

ountain_Lion_(Puma)_-_Desert_Museum_-

_Tucson_-AZ_-_2015-10-12at10-24-

247_(22066481590).jpg)

Overweight No hips or ribs showing, rotund appearance to 

abdomen

Obese Abdomen sagging, obvious fat over hips and 

shoulders

Source unless otherwise noted: USDA-APHIS
--- Animal Care Inspection Guide ---

Savedate 12/7/2021 9:38 AM Body Condition and Size Charts E-4

Dog

Emaciated Ribs and lumbar vertebrae obvious, pelvic bones 

and all other bony structures obvious and 

prominent. Tail base prominent and bony. 

Accentuated concave abdominal tuck. 

Accentuated, severe hourglass shape to waist. 

No discernible body fat. Obvious loss of muscle 

mass.

Underweight Ribs and lumbar vertebrae easily seen with no fat 

cover. Pelvic bones obvious. Tail base bony with 

little soft tissue. Marked concave abdominal 

tuck. Marked hourglass shape to waist.

Optimal body weight Ribs, lumbar vertebrae, pelvic bones, and other 

bony structures easily palpable with slight fat 

cover. Tail base smooth with thin, soft tissue 

cover. Concave abdominal tuck. Smooth 

hourglass shape to waist.

Overweight Ribs and lumbar vertebrae are difficult to 

palpate. Pelvic bones are palpable with 

moderate tissue cover. Tail base has fat 

deposition with moderate soft tissue cover. 

Concave tuck is decreased to absent. Loss of 

hourglass shape to waist with back is slightly 

broadened.

Obese Ribs and lumbar vertebrae are very difficult to 

impossible to palpate. Pelvic bones are difficult 

to palpate with thick tissue cover. Tail base is 

thickened from fat disposition with thick soft 

tissue cover. Abdomen is convex with or without 

a pendulous ventral bulge. Back is markedly 

broadened.

(https://upload.wikimedia.org/wikipedia/commo

ns/a/aa/AHey_Fatty.jpg)

Source unless otherwise noted: USDA-APHIS
--- Animal Care Inspection Guide ---

Savedate 12/7/2021 9:38 AM Body Condition and Size Charts E-5

Elephant

Emaciated All ribs and vertebral bodies prominently 

showing, skin laying over hips and femur

Underweight Ribs, vertebral bodies and hips slightly showing, 

“tucked up” appearance

Optimal body weight Hint of ribs and vertebral bodies, good muscle 

tone

Overweight No hips or ribs showing, rotund appearance to 

abdomen

Obese Abdomen sagging, obvious fat over hips and 

shoulders

Source: USDA-APHIS
--- Animal Care Inspection Guide ---

Savedate 12/7/2021 9:38 AM Body Condition and Size Charts E-6

Leopard

Emaciated All ribs and vertebral bodies prominently 

showing, skin laying over hips and femur

Underweight Ribs, vertebral bodies and hips slightly showing, 

“tucked up” appearance

Optimal body weight Hint of ribs and vertebral bodies

Source

Photo by Patrick Giraud courtesy of Wikimedia 

Commons 

(http://en.wikipedia.org/wiki/File:Namibie_Etosh

a_Leopard_01edit.jpg)

Overweight No hips or ribs showing, rotund appearance to 

abdomen

Obese Abdomen sagging, obvious fat over hips and 

shoulders

Source: USDA-APHIS
--- Animal Care Inspection Guide ---

Savedate 12/7/2021 9:38 AM Body Condition and Size Charts E-7

Lion

Emaciated All ribs and vertebral bodies prominently 

showing, skin laying over hips and femur

Underweight Ribs, vertebral bodies and hips slightly showing, 

“tucked up” appearance

Optimal body weight Hint of ribs and vertebral bodies

Overweight No hips or ribs showing, rotund appearance to 

abdomen

Obese Abdomen sagging, obvious fat over hips and 

shoulders

Source: USDA-APHIS
--- Animal Care Inspection Guide ---

Savedate 12/7/2021 9:38 AM Body Condition and Size Charts E-8

Tiger

Emaciated All ribs and vertebral bodies prominently 

showing, skin laying over hips and femur

Underweight Ribs, vertebral bodies and hips slightly showing, 

“tucked up” appearance

Optimal body weight Hint of ribs and vertebral bodies

Source

Photo by J&K Hollingsworth, U.S. Fish and 

Wildlife Service

Overweight No hips or ribs showing, rotund appearance to 

abdomen

Obese Abdomen sagging, obvious fat over hips and 

shoulders

Source: USDA-APHIS
--- Animal Care Inspection Guide ---

Savedate 12/7/2021 9:38 AM Body Condition and Size Charts E-9

Tiger cub size information

Generic Bengal tiger cub weights are listed in Table D-1. Siberian tigers or Siberian/Bengal cross tiger 

cubs will be somewhat larger and often have longer, fuzzy hair. Females will often be a little smaller 

than males as they grow older. Birth weight is about 2.5 to 3.5 pounds.

Age Weight (pounds) Photograph

1 week 4.5 – 6.0

Source: Point Defiance Zoo, Tacoma WA, 

http://zooborns.com

2 weeks 6.0 – 7.5

Source: San Diego Zoo, San Diego CA, 

http://sdzoo.tumblr.com
--- Animal Care Inspection Guide ---

Savedate 12/7/2021 9:38 AM Body Condition and Size Charts E-10

Age Weight (pounds) Photograph

3 weeks 7.5 – 9.0

Source: Point Defiance Zoo, Tacoma WA, 

http://zooborns.com

4 weeks 9 – 10

Source: http://zooborns.com

5 weeks 10 – 12

Source: http://zooborns.com
--- Animal Care Inspection Guide ---

Savedate 12/7/2021 9:38 AM Body Condition and Size Charts E-11

Age Weight (pounds) Photograph

6 weeks 12 – 15

Source: Point Defiance Zoo, Tacoma WA 

http://zooborns.com

7 weeks 14 – 17

Source: Point Defiance Zoo, Tacoma WA 

http://zooborns.com

8 weeks 16 – 19

Source: The Calgary Herald, 

http://www.calgaryherald.com/index.html
--- Animal Care Inspection Guide ---

Savedate 12/7/2021 9:38 AM Body Condition and Size Charts E-12

Age Weight (pounds) Photograph

10 weeks 19 – 25

Source: USDA APHIS

12 weeks 24 – 40

Source: http://zooborns.com

16 weeks 35 – 50

Source: Wildlife Heritage Foundation http://www.flickr.com
--- Animal Care Inspection Guide ---

Savedate 12/7/2021 9:38 AM Body Condition and Size Charts E-13

Age Weight (pounds) Photograph

20 weeks 55 – 68

Source: Bronx Zoo, Bronx NY http://bronxzoo.com
--- Animal Care Inspection Guide ---

Savedate 12/7/2021 9:38 AM Acronyms F-1

Acronyms

AAALAC Association for Assessment and 

Accreditation of Laboratory Animal 

Care International

AALAS American Association for Laboratory 

Animal Science

AC Animal Care – a division of USDA, 

APHIS

ACI Animal Care Inspector

AD Assistant Director of Animal Welfare 

Operations

APHIS Animal and Plant Health Inspection 

Service

AV Attending Veterinarian

AVMA American Veterinary Medical 

Association

AWA Animal Welfare Act

AWIC Animal Welfare Information Center

AWO Animal Welfare Operations

CFR Code of Federal Regulations

DRA Dry resting area

FOIA Freedom of Information Act

IACUC Institutional Animal Care and Use 

Committee

ID Identification

IES Investigative and Enforcement 

Services

ILA Inspection and Licensing Assistant

ILAR Institute for Laboratory Animal 

Research

IO Institutional Official

LOW Letter of Warning (APHIS Form 7060)

MHD Minimum horizontal dimension

MM Marine mammal

NCI Noncompliant item

NHP Nonhuman primate

NIH National Institutes of Health

NRC National Research Council

OGC Office of the General Counsel 

OIG Office of Inspector General

OLAW Office of Laboratory Animal Welfare

PI Principle Investigator

PII Personally Identifiable Information

PPQ Plant Protection and Quarantine

PRN Pro Re Nata, as needed

PS Program Support

PVC Program of veterinary care

RBIS Risk based inspection system

SACS Supervisory Animal Care Specialist

SOTW SACS of the Week

SPF Specific pathogen free

TIN Taxpayer identification number

TRA Traveling on the road site 

designation in eFile

USC United States Code

USDA United States Department of 

Agriculture

USDI United States Department of Interior

VMO Veterinary Medical Officer
--- Animal Care Inspection Guide ---

Index

Under construction