Animal Welfare Inspection Guide

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employer.

Revised March 2024
Contents

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Introduction 1-1

1.1. Purpose 1-1

1.2. Disclaimer 1-2

1.3. Meaning of Must, Should, and May 1-3

1.4. Meaning of Bulleted and Numbered Lists 1-4

1.5. Using the Inspection Guide 1-5

1.6. Inspection Guide Updates 1-6

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 2-12

2.6. Inspection Inventory 2-14

2.7. Exit Interview 2-18

2.8. Delivery of the Inspection Report 2-19

2.9. ACI Team Inspection with a VMO after a Veterinary Care Direct 2-20

2.10. Risk Based Inspection System (RBIS) 2-21

2.11. Deciding Not to Conduct an Inspection 2-22

2.12. Attempted Inspection 2-23

2.13. Prelicense Inspection 2-24

2.14. Refusal of Inspection 2-25

2.15. Interference 2-26

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

Inventory 2-27

2.17. Inspection Report Review 2-28

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 3-24

3.4. Safety and Ethics Issues 3-42

Specific Types of Inspections 4-1

4.1. Airport Inspection 4-5

4.2. Animal Rides 4-7

4.3. Attempted Inspections 4-9

4.4. Auction Market Inspection 4-17

4.5. Barrier Facility Inspection 4-20

4.6. Change in Class of License Inspection 4-22

4.7. Complaint Inspection Procedure 4-24

4.8. Courtesy Visits 4-27
4.9. Dead Animal/Parts or Serum/Blood Dealer Inspection 4-30

4.10. Dogs and Cats in Residence Inspection 4-32

4.11. Domestic Hoofstock Inspection 4-34

4.12. Drive-through Zoo/Park Inspection 4-35

4.13. Lion and Tiger Enclosure Inspection 4-43

4.14. Marine Mammal Facility Inspections 4-45

4.15. New Site Approval Inspection 4-53

4.16. Pet Store Inspection 4-55

4.17. Petting Zoo Inspection 4-57

4.18. Photo Shoot Inspection 4-61

4.19. Prelicense Inspection Process 4-64

4.20. Public Walk-In Aviary Inspection 4-74

4.21. Search Inspection 4-78

4.22. Traveling Exhibitor Inspection 4-83

4.23. Wild/Exotic Animal Auction Inspection 4-94

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 6-8

6.3. Records 6-11

6.4. Inspection Guidance 6-15

6.5. Documentation of Veterinary Care NCIs 6-29

Research Facility Inspection 7-1

7.1. IACUC Review Information 7-3

7.2. Protocol Review Information 7-11

7.3. Veterinary Care Requirements for Dogs 7-23

7.4. Contracted Research or Projects that Involve Multiple Registrants 7-26

7.5. Records 7-28

7.6. Guidance for Veterinary Schools and Veterinary Technician Programs (VTP) 

for the Inspector 7-35

7.7. Termination of a Registration 7-37

7.8. Holding Period 7-38

7.9. Research Facility Protocol Selection Worksheet 7-39

Confiscation Guidance 8-1

8.1. 8.1Criteria for Confiscation 8-3

8.2. Documentation 8-14

8.3. Body Condition and Age Assessment Charts 8-17

8.4. Guidelines and Responsibilities for the Confiscation of Animals 8-30

8.5. Sample Documents 8-41

Appendix A. 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

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

Unsatisfactory Optimal Hours Response Letter A-19

Bird Breeder/Exhibitor Pre-License List A-20

Appendix B. 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

Appendix C. NCI/Direct/Critical Noncompliance Examples C-1

Examples for Dogs and Cats C-3

Examples for Other Animals C-14

Appendix D. Equipment and Supplies D-1

Appendix E. Body Condition and Size Charts E-1

Birds E-2

Cat E-3

Cougar E-4

Dog E-5

Elephant E-6

Leopard E-7

Lion E-8

Tiger E-9

Tiger cub size information E-10

Appendix F. Acronyms F-1
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Introduction

Contents

1.1. Purpose 1-1

1.2. Disclaimer 1-2

1.3. Meaning of Must, Should, and May 1-3

1.4. Meaning of Bulleted and Numbered Lists 1-4

1.5. Using the Inspection Guide 1-5

1.5.1. Questions or Concerns with the Inspection Guide 1-5

1.6. Inspection Guide Updates 1-6
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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.

1.5.1. 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

LIST OF UPDATES MADE TO THE FEBRUARY EDITION OF THE INSPECTION GUIDE

Section 2.8 Delivery of Inspection Report – Delivery of Attempted Inspections – Clarified guidance for 

delivery of all repeat AIs

Section 4.8 Courtesy Visits – Revised

Section 4.12 – Drive Thru Zoo/Park Inspection 

Section 4.12.3 – Handling – Revised

Section 4.12.4 – Public Feeding - Revised

Section 4.19.2.1 – Conducting the Inspection – Added maximum number of dogs to inspect 

Section 7.1.2 – Review of the Program of Humane Care and Use and Facility Inspection

• Live Video guidance removed

• Use of Subcommittees guidance added
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Required Inspection Procedures

Contents

2.1. Required Inspection Procedures 2-3

2.1.1. General Requirements 2-3

2.2. Safety 2-4

2.2.1. Inspector Safety 2-4

2.2.2. Biosafety 2-4

2.3. Inspection Steps 2-5

2.4. Inspection Findings 2-6

2.4.1. No Noncompliant Items (NCIs) Identified 2-6

2.4.2. New NCIs Cited 2-6

2.4.3. Repeat NCI 2-7

2.4.4. Recurring/Chronic NCI 2-7

2.4.5. “Critical” NCI Identified 2-8

2.4.6. “Direct” NCI Identified 2-9

2.4.7. Correction Date Guidelines 2-9

2.4.8. Direct NCI on a New Site Approval Inspection 2-9

2.4.9. “Veterinary Care Direct” NCI Identified 2-10

2.4.10. Handwritten or “Word” Inspection Reports 2-10

2.4.11. Airport Inspections 2-11

2.5. Inspection Photographs 2-12

2.5.1. Photographs/Videos Documenting Noncompliances 2-12

2.5.2. Showing Photos during Exit Interview 2-13

2.5.3. Licensee/Registrant Requesting Photographs 2-13

2.6. Inspection Inventory 2-14

2.6.1. Before the Inspection 2-14

2.6.2. During the Inspection 2-14

2.6.3. After the Inspection 2-16

2.7. Exit Interview 2-18

2.8. Delivery of the Inspection Report 2-19

2.8.1. Signature on the Inspection Report 2-19

2.9. ACI Team Inspection with a VMO after a Veterinary Care Direct 2-20

2.10. Risk Based Inspection System (RBIS) 2-21

2.11. Deciding Not to Conduct an Inspection 2-22

2.12. Attempted Inspection 2-23

2.13. Prelicense Inspection 2-24

2.14. Refusal of Inspection 2-25

2.15. Interference 2-26

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

Inventory 2-27

2.16.1. Correcting an Inspection Report and/or Inventory 2-27
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2.16.2. Rescinding and Amending an Inspection Report and/or Inventory 2-27

2.17. Inspection Report Review 2-28

2.17.1. Inspection Report Review 2-28

 

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.

2.1.1. 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

2.2.1. 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]

2.2.2. 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 shoe covers during avian inspections in areas that are not

open to the public

• 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 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, Contingency Plan, and, when appropriate, the “Exercise 

Plan for Dogs”, and the plan for environmental enhancement for nonhuman 

primates (Optional APHIS Form 7050 may be used) and/or birds

• 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.

2.4.1. 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.”

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.”

2.4.2. 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.

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.
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2.4.3. Repeat NCI

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

focused or Relicense) or cited at least 3 times within the past three years

(including the current citation) 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.

2.4.4. 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?

• 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

NOTICE

On Prelicense Inspections or New Site Approval Inspection, an NCI should not 

be designated as a “Repeat”.
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• Discussing the NCI with your SACS

2.4.5. “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 

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 
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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

2.4.6. “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.

2.4.7. 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.

2.4.8. 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

NOTICE

On Prelicense Inspections, NCIs should not be designated as “Direct.”
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• Inform the licensee that an inspection will be conducted on or after the 

correction date to see if the Direct NCI was corrected

2.4.9. “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.

2.4.10. 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

• 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
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• 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.

2.4.11. 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. 
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2.5. Inspection Photographs

2.5.1. 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

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 
--- Animal Care Inspection Guide ---

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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.

2.5.2. 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.

2.5.3. 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. 
--- Animal Care Inspection Guide ---

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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. 

2.6.1. 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)

2.6.2. During the Inspection

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. 

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

• Many birds kept in a large aviary

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

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

• Breeding or nesting birds in a nest box

• 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 as a noncompliance on 
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the Inspection Report. When this occurs, you should estimate the animal 

numbers present and use that number on the inventory; it should be made clear 

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.

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.

2.6.3. 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. 

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 
--- Animal Care Inspection Guide ---

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

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 must be discussed during the exit interview.
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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. 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

2.8.1. 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
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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 and certified mail. 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. 

2.16.1. 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.

2.16.2. 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 Review

The SACS or his/her designee must review the Inspection Reports in eFile as soon 

as possible but no longer than 21 days from the date the report is finalized.

2.17.1. 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.
--- Animal Care Inspection Guide ---

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General Inspection Procedures

Contents

3.1. Preparing for the Inspection 3-3

3.1.1. Translation Services 3-3

3.2. Conducting the Inspection 3-4

3.2.1. General Information 3-4

3.2.2. Inspection on Native American Land 3-5

3.2.3. Biosafety Measures 3-5

3.2.4. Animal Inspection – Specific Guidance 3-7

3.2.5. Facility Inspection — Specific Guidance 3-15

3.2.6. Contingency Planning 3-20

3.2.7. Non-Disclosure Agreements 3-21

3.2.8. Miscellaneous Inspection Guidance 3-21

3.3. Completing the Inspection Report 3-24

3.3.1. General Information 3-24

3.3.2. Changes in Business Information 3-25

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

Database 3-25

3.3.4. Traveling (TRA) Site 3-26

3.3.5. Type of Inspection 3-26

3.3.6. Inspection Report Narrative 3-27

3.3.7. Examples of Citations 3-27

3.3.8. Information Inspectors Should Not Include in the Narrative 3-30

3.3.9. Repeat Noncompliant Item Identified 3-31

3.3.10. Direct Noncompliant Item Identified 3-31

3.3.11. Critical Noncompliant Item Identified 3-31

3.3.12. Noncompliant Item with Correction Time Remaining 3-31

3.3.13. No Regulated Animals Present 3-32

3.3.14. Non-regulated Animals 3-33

3.3.15. Correction Date 3-33

3.3.16. Prior to Printing the Final Inspection Report 3-35

3.3.17. Finalizing the Inspection Report 3-36

3.3.18. Handwritten Inspection Reports 3-36

3.3.19. Mistakes on the Inspection Report 3-37

3.3.20. Correcting or Amending the Inspection Report 3-38

3.3.21. Inspection Appeals Process [2.13] 3-39

3.4. Safety and Ethics Issues 3-42

3.4.1. Bribery Reporting Procedures—Inspector’s Responsibility 3-42

3.4.2. Bribery Reporting Procedures—Supervisor’s Responsibility 3-43

3.4.3. Gifts from Licensee/Registrant 3-43

3.4.4. Interference with the Inspection 3-43
--- 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)

3.1.1. 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.

3.2.1. 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, 

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

pay the fee yourself and you will be reimbursed.

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 3/8/2024 12:55 PM General Inspection Procedures 3-5 

• 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

3.2.2. 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.

3.2.3. 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 protefctive 

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)

Coveralls (optional)

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.
--- Animal Care Inspection Guide ---

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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)

Birds General Recommendations for all facilities:

• Always conduct an inspection outside of an avian 

enclosure if possible

• Wash car frequently

• Park as far away from the entrance that is safe 

and reasonable

• Limit exposure with personally owned birds 

before and after inspections that day

• Wear gloves if you will need to be touching or 

holding objects from the facility

• Wear additional PPE (such as, respirator (N-95 or 

higher), coveralls or disposable gowns, 

disposable caps, or protective eyewear) if you 

are more vulnerable to infections or the aviary is 

significantly dirty

• Minimalize equipment brought into the facility if 

not necessary

• Refrain from inspecting in areas where active 

cleaning & sanitizing is going on

• Conduct the inspection starting from the most 

vulnerable birds first. This is commonly the 

nursery first, next the feed storage/kitchen, then 

the general aviary, and lastly the quarantine and 

hospital area.

Open to the public avian facilities:

• Follow the facility’s biosecurity protocols
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• Biosecurity precautions may increase based on 

outbreak risk in the area

Not open to the public avian facilities:

• Follow the facility’s biosecurity protocols

• Wear a new disposable shoe covers or sanitized 

boots

• Wash hands with soap or hand-sanitizer before 

and after entering the facility

• Wipe down all hard surfaces of equipment 

brought into the facility with a sanitizing agent 

(such as camera, pens, outside of notebook) 

before and after entering the facility

• Have not visited an avian facility on that day 

beforehand

• Biosecurity precautions may increase based on 

outbreak risk in the area

Special Note: Immediately notify your SACS if you 

see or the facility reports a sudden and significant 

illness or death loss in their aviary.

3.2.4. Animal Inspection – Specific Guidance

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
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• Make sure all animals are safely secured

• 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 

Field 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]:

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

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)

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 
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its enclosure at a reasonable distance from the enclosure

• 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. 
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Recognize this behavior and step away from the enclosure before the cat 

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) 
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behind a barrier so that an inspection of the animal’s feet, skin, teeth, and other 

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 non-
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threatening to the animals.

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.

3.2.4.2.6 Birds

Almost all bird species are considered prey species with a few exceptions; birds 

in general are easily stressed by human presence. Sudden movements or any 

new or unfamiliar objects or person(s) will cause stress and be viewed as a 

potential threat initially. Avoid making exaggerated or quick gestures. Many 

birds are sensitive to sounds, so try to minimalize noises. This includes picking up 

your feet when walking, avoid speaking in a loud voice, keeping your phone on 

“vibrate”, minimizing the number of people near the avian enclosure, and 

limiting the number of objects you are carrying such as a handbag or backpack. 

When inspecting around parrots it may be comforting to gently talk to the 

animal. When inspecting around a nervous bird it may be better to look at them 

sideways or with one eye and not stare at them directly with both eyes. If there 

is a way to shield yourself from the bird’s view that is preferred. Additionally, try 

to inspect diurnal birds while you are in as much light as possible so the bird can 

see you and avoid standing in the shadows. If it is necessary to take a picture 

avoid using the flash. Forgo wearing sparkly jewelry or large amounts of 

perfume, cologne, or other products with a strong odor. Try to minimalize 

disruptions during breeding, hatching, and sleeping times as much as possible.

BEWARE: Most avian species have a sharp beak and nails that can bite and 

scratch the skin. It’s always recommended that you conduct an inspection 

outside of an avian enclosure. For large, public aviaries where you may need to 

go inside the enclosure with free flying birds, always be aware of your 

surroundings and know your exits. During periods of breeding and hatching 

many species will have an increase in aggressive behaviors. And always be 

extremely careful around any active nests. Keep in mind a sick or threatened bird 

may be more aggressive and will attack the face and eyes. Additionally, there are 

several species groups you need to be more cautious around. 

Parrots have an extremely high biting force with their beaks and can cause 
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severe injuries to fingers, hands, and the face. Furthermore, birds can be 

extraordinarily quick in their strikes, especially with strangers or during breeding 

or hatching times. Allow for enough distance away from the cage that you are 

not within biting range. Even with correctly sized enclosures, most birds can stick 

their beaks several inches outside the cage or use the tip of the beak to hook and 

draw in an object. Consider ear protection when working around birds, especially 

psittacines. Several species of birds, such as the Nanday Conure, have a decibel 

range up to 155dB. This is comparable to firecrackers and jet engines. Finally, 

while most birds produce a dander-like substance from their feathers, cockatoos, 

cockatiels, and amazon greys produce a large amount of fine powder that can 

cause some people to have an allergic reaction. If you are sensitive to bird 

dander wear a respirator and keep your distance from these species.

Gallinaceous birds (e.g., pheasants, turkeys, and other land fowl) have sharp 

spurs on their legs and screamers, a South American duck-like species, have a 

large spur on the first digit of the wing. While best to avoid being in the same 

enclosure with a spur equipped bird, if you are, keep your distance, never turn 

your back to the bird, and know your exits. If you feel any concern about your 

safety or the bird is displaying any signs of aggression, leave the area 

immediately. 

Many sharp beaked shore or water birds such as cranes, herons, egrets, and 

cormorants can mistake the reflection in people’s eyes as the flash of a fish in 

the water. These species are extremely fast and are equipped with a sharp beak 

designed to hold-on to slippery fish. Bites from their beak can easily cut humans 

and all handlers should always wear eye protection. Inspectors should not 

approach these animals and should wear eye protection if in the same physical 

space.

Raptors not only have a sharp beak used for tearing into flesh but also have 

sharp talons with a high gripping strength that can rival the jaw strength of many 

big cats. Unless under the control of a trained handler, you should never be in 

the same space with a raptor.

Large birds such as ostriches, emus, and cassowaries have powerful legs with 

long claws that will charge, kick, and sometimes jump on top of a person or 

animal that they perceive as a threat. People have been killed by these birds and 

you should never be in the same enclosure with these types of birds.

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
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• Labored breathing/open-mouthed breathing

• Fractured or dislocated limb

• Severe bleeding or injury

• Severe, watery, or bloody diarrhea

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

• Inspectors should discuss with licensees the issues of non-containment and 

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

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. 

3.2.5. Facility Inspection — Specific Guidance

The inspector must develop a consistent method for inspecting facilities that 
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ensures inspections are thorough, accurate, and all citations are based on the 

Regulations and Standards. 

Guidance on specific issues related to facility inspection include:

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 

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 
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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 

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

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.

Perimeter Fence

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

The perimeter fence requirements are:
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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 

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
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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.

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.

3.2.5.3.3 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, 
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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. 

3.2.6. Contingency Planning 

Contingency planning regulations require all licensees and registrants to develop, 

document, and follow an appropriate plan to provide for the humane handling, 

treatment, transportation, housing, and care of their animals in the event of an 

emergency or disaster. 

In reviewing a contingency plan, check that the following required components 

are specified in the plan:

• When is the plan triggered

• What actions are to be taken

• Who is responsible for the actions, and

• How will the actions be accomplished with respect to materials and training

• Written documentation that the plan is reviewed and updated annually

Note that while written training records are not required, it is permissible to 

confirm verbally that training for new employees hired after August 3, 2022 had 

been conducted within 30 days of hire.

Licensees and registrants may use the APHIS Form 7093 but it is not required. 

The intent of the Contingency Plan is to encourage licensees and registrants to 

think through possible emergencies and plan ahead. Animal Care does not 

intend to collect or evaluate the quality and effectiveness, post-event, of any 

plan. 

 

NOTICE

Marine Mammals have additional Contingency Plan requirements. 

See Section 4.14 Marine Mammal Facility Inspections.
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3.2.7. Non-Disclosure Agreements

Non-disclosure agreements (NDA) are contracts by which a party agrees not to 

disclose confidential information, as part of doing business together. Some 

facilities may have staff and/or veterinarians sign NDAs as a condition of 

employment. NDAs do not relieve the responsibility of a licensee, carrier, or 

intermediate handler from furnishing information that an inspector or other 

APHIS official has requested in connection with enforcement of the AWA. If you 

find that you are not able to obtain the information you require for an inspection 

due to an NDA, please contact your SACS for further guidance.

3.2.8. Miscellaneous Inspection Guidance

Authorized Person Conducting Regulated Activity

An authorized person can represent the licensee during a USDA inspection. 

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.

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
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Savedate 3/8/2024 12:55 PM General Inspection Procedures 3-22 

• 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. 

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 

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.

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:

NOTICE

Remember that you cannot work overtime without your SACS approval.
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Savedate 3/8/2024 12:55 PM General Inspection Procedures 3-23

o A memo documenting the situation and the action taken

o The Inspection Report, if appropriate

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

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

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.

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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Savedate 3/8/2024 12:55 PM General Inspection Procedures 3-24 

3.3. Completing the Inspection Report

3.3.1. 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 Inspection Site in 

eFile before beginning the report by checking the site number, status, and 

verifying that the address listed is the physical location you inspected.

• 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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3.3.2. 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

3.3.3. 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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Savedate 3/8/2024 12:55 PM General Inspection Procedures 3-26 

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. 

3.3.4. 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

3.3.5. 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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Savedate 3/8/2024 12:55 PM General Inspection Procedures 3-27

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 Compliance Assurance 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

3.3.6. Inspection Report Narrative

Refer to Inspection Findings in Chapter 2 for instructions on documenting 

inspection findings in the narrative section of the Inspection Report.

3.3.7. 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.

EXAMPLE Standard: 3.158(a) CLEANING

Noncompliance: An enclosure with 50 adult zebra finches had an 

excessive accumulation of feces on the perches, nest boxes, and 

floor of the enclosure. Multiple birds were seen with feces 

attached to their feet and tails.

Why a noncompliance: Excreta must be removed from primary 

enclosures as often as necessary to prevent excessive 

accumulation of feces to prevent soiling of the birds contained in 

the primary enclosures, and to reduce disease hazards, insects, 

pests, and odors.

How to comply: Remove excreta from the bird’s primary 

enclosures to prevent excessive accumulation of feces. This 

includes removing excreta to prevent soiling of the birds contained 

in the primary enclosures.

Correction date: Correct by (date).

3.3.8. 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
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Savedate 3/8/2024 12:55 PM General Inspection Procedures 3-31 

• 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

• Recommended enforcement action

3.3.9. Repeat Noncompliant Item Identified

Refer to Repeat NCI in Chapter 2 for information on Repeat noncompliant items.

3.3.10. Direct Noncompliant Item Identified

Refer to “Direct” NCI Identified in Chapter 2 for information on Direct 

noncompliant items.

3.3.11. Critical Noncompliant Item Identified

Refer to “Critical” NCI Identified in Chapter 2 for information on Critical 

noncompliant items.

3.3.12. Noncompliant Item with Correction Time Remaining

Focused Inspection

If you are conducting a “focused” inspection, such as follow up on a Direct or 

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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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.

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.

3.3.13. 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 

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 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 
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Savedate 3/8/2024 12:55 PM General Inspection Procedures 3-33 

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

3.3.14. 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).

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

3.3.15. 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, 

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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Savedate 3/8/2024 12:55 PM General Inspection Procedures 3-34 

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

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

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.

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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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

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

3.3.16. 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
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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

• 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.

3.3.17. 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.)

3.3.18. 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, 

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.”

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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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 

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.

3.3.19. 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.

Major Errors

If a major error is noted on the Inspection Report after the final copy has been 
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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

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

3.3.20. 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

NOTICE

Spelling or grammatical errors are not considered major errors.
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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

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.

3.3.21. 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.

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 

NOTICE

The ‘prepared by’ and ‘signed by’ dates do not have to be the same.
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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

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:

• 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. 
--- Animal Care Inspection Guide ---

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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

3.4.1. 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.

3.4.2. 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

3.4.3. 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.

3.4.4. 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 4-5

4.1.1. Badging Credentials 4-5

4.1.2. Conducting an Airport Inspection 4-5

4.1.3. Inspection Reports 4-6

4.1.4. Photographs 4-6

4.2. Animal Rides 4-7

4.2.1. Criteria 4-7

4.2.2. Conducting the Inspection 4-7

4.2.3. Inspection Reports 4-8

4.3. Attempted Inspections 4-9

4.3.1. Attempted Inspection General Procedures 4-9

4.3.2. Courtesy Visits 4-11

4.3.3. Conducting an Unannounced Inspection after the Courtesy Visit 4-12

4.3.4. Compliance Assurance Staff (CAS) 4-13

4.3.5. Compliance Assurance Staff (CAS) Referral 4-13

4.3.6. Additional Attempted Inspection Guidance 4-13

4.3.7. The Facility Contact Worksheet 4-14

4.3.8. Optimal Hours 4-15

4.3.9. Handy Tips 4-15

4.4. Auction Market Inspection 4-17

4.4.1. Criteria 4-17

4.4.2. Animals Requiring Veterinary Care 4-18

4.4.3. Records 4-18

4.5. Barrier Facility Inspection 4-20

4.5.1. Criteria 4-20

4.5.2. Alternative Methods of Inspection 4-21

4.6. Change in Class of License Inspection 4-22

4.6.1. Criteria 4-22

4.6.2. Conducting the Inspection 4-23

4.7. Complaint Inspection Procedure 4-24

4.7.1. Sources of Information 4-24

4.7.2. Outside Complaints received by AWO Inspector 4-24

4.7.3. Complaint Notification, Tasks, & Supervisor Discussion 4-25

4.7.4. Complaint Inspection & Closure 4-25

4.8. Courtesy Visits 4-27

4.8.1. General Information 4-27

4.8.2. Documenting a Courtesy Visit 4-27

4.8.3. Conducting the Courtesy Visit 4-28

4.9. Dead Animal/Parts or Serum/Blood Dealer Inspection 4-30
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4.9.1. Dead Animal/Parts 4-30

4.9.2. Blood and Serum Collection 4-30

4.10. Dogs and Cats in Residence Inspection 4-32

4.11. Domestic Hoofstock Inspection 4-34

4.11.1. Domestic Hoofstock Housed in an Agricultural Setting 4-34

4.11.2. Domestic Hoofstock Housed in a Non-Agricultural Setting 4-34

4.12. Drive-through Zoo/Park Inspection 4-35

4.12.1. Conducting the Inspection 4-35

4.12.2. Animal Inspection 4-36

4.12.3. Handling 4-36

4.12.4. Public Feeding 4-37

4.12.5. Facility Inspection 4-38

4.13. Lion and Tiger Enclosure Inspection 4-43

4.13.1. Evaluating Enclosures 4-43

4.14. Marine Mammal Facility Inspections 4-45

4.14.1. Conducting the Inspection 4-45

4.14.2. Veterinary Care 4-45

4.14.3. Space 4-46

4.14.4. Feeding 4-47

4.14.5. Water Quality 4-48

4.14.6. Shelter and Shade 4-49

4.14.7. Public Barriers 4-50

4.14.8. Separation 4-51

4.14.9. Employees 4-51

4.14.10. Contingency Plan for Water and Electric Power 4-52

4.14.11. Recordkeeping 4-52

4.14.12. Swim-with-the-dolphin (SWTD)/Interactive Programs 4-52

4.15. New Site Approval Inspection 4-53

4.15.1. Addition of a Site 4-53

4.15.2. Site Inspection 4-53

4.16. Pet Store Inspection 4-55

4.16.1. Criteria 4-55

4.16.2. Record Requirements 4-56

4.16.3. Identification 4-56

4.17. Petting Zoo Inspection 4-57

4.17.1. Inspection Procedures 4-57

4.17.2. Traveling Petting Zoo Itinerary 4-59

Animal Information 4-59

Exhibition and Transport Information: 4-60

4.18. Photo Shoot Inspection 4-61

4.18.1. Types of Photo Shoots 4-61

4.18.2. Conducting the Inspection 4-62

4.19. Prelicense Inspection Process 4-64

4.19.1. Initial Contact with the Applicant 4-64

4.19.2. First Prelicense Inspection 4-65

4.19.3. Second Prelicense Inspection 4-67
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4.19.4. Third Prelicense Inspection 4-68

4.19.5. Completing the Inspection Report 4-68

4.19.6. Photographs 4-71

4.19.7. Relicensing 4-71

4.19.8. PL Inspection Process Reminders 4-73

4.20. Public Walk-In Aviary Inspection 4-74

4.20.1. Exterior Aviary Check & Entering 4-74

4.20.2. Inside the Aviary 4-74

4.20.3. Public Feeding and Public Interaction 4-77

4.20.4. Recordkeeping 4-77

4.21. Search Inspection 4-78

4.21.1. Subjects of Searches 4-78

4.21.2. Sources of Information 4-78

4.21.3. Information Follow-Up 4-79

4.21.4. Preparing for the Search 4-79

4.21.5. Conducting the Search 4-80

4.21.6. Documenting Search Results in eFile 4-81

4.21.7. Follow-Up Procedure 4-81

4.21.8. On the Road Inspection 4-82

4.22. Traveling Exhibitor Inspection 4-83

4.22.1. Home Site Inspection 4-83

4.22.2. General Information 4-83

4.22.3. Admission to the Venue 4-84

4.22.4. Conducting the Inspection 4-85

4.22.5. Animals in Transit 4-89

4.22.6. Animal Races 4-90

4.22.7. Animal Rides 4-90

4.22.8. Circus and Performing Animal Inspections 4-90

4.22.9. Petting Zoos 4-92

4.22.10. Photo Shoots 4-92

4.22.11. Inspection Reports 4-92

4.22.12. Itinerary 4-93

4.23. Wild/Exotic Animal Auction Inspection 4-94

4.23.1. Licensing Requirements 4-94

4.23.2. Regulatory Responsibilities 4-95

4.23.3. Inspection Procedures 4-95

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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--- Animal Care Inspection Guide ---

Savedate 3/8/2024 12:55 PM Specific Types of Inspections 4-5

4.1. Airport Inspection

Registered Transporters or Intermediate Handlers operating at an airport must

meet all applicable transportation Regulations and Standards.

4.1.1. 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. 

4.1.2. 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”

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.

4.1.3. Inspection Reports

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. 

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

4.1.4. 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.

4.2.1. Criteria

Examples of regulated animals used for rides are:

• Camels

• Elephants

• Llamas

4.2.2. 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
--- Animal Care Inspection Guide ---

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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

4.2.3. 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.

4.3.1. 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
--- Animal Care Inspection Guide ---

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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 the third attempted inspection in the past two

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.

4.3.2. 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, which 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, Field Specialists, compliance specialists, etc.)

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 third attempted inspection in two 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

Conducting a Courtesy Visit

A courtesy visit will be offered to all facilities receiving their first repeat
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attempted (i.e., two consecutive attempted inspections or the third attempted 

inspection in two 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. 

4.3.3. 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: 

• Follow the Attempted Inspection Procedures (not including the courtesy visit)

• Document the attempt on an inspection report, and
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• Designate it as a “repeat” (second repeat)

• This facility will be referred to the Compliance Support Staff

4.3.4. Compliance Assurance Staff (CAS)

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 CAS.

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).

4.3.5. Compliance Assurance Staff (CAS) Referral

A facility will be referred to RSS for possible license revocation after the fourth 

Attempted Inspection (third repeat Attempted Inspection).

4.3.6. 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, and talking points are accepted 

and implemented to improve the health and well-being of all regulated animals.

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 

completing an inspection around these days.

• Old Christmas (6 January)

• Good Friday & Easter Monday (Friday & Monday prior to and following
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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

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

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.

4.3.7. The Facility Contact Worksheet

The Facility Contact Worksheet should be updated, as needed, to maintain 

current optimal hours, contact information, and facility representative 

information. 
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Savedate 3/8/2024 12:55 PM Specific Types of Inspections 4-15 

This worksheet must be uploaded into eFile within five business days. 

4.3.8. 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, which 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.

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”. 

4.3.9. 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

• 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 
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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

4.4.1. 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

 

4.4.2. 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.

4.4.3. Records

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.

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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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.

4.5.1. 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.

4.5.2. Alternative Methods of Inspection

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

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.

4.6.1. 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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4.6.2. Conducting the Inspection

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

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 Procedure

4.7.1. Sources of Information

• Sources of information include, but are not limited to:

• General public

• Customer or stakeholder

• Non-government organization

• Another Federal agency

• City, county, or State agency

• Verbally via another AC employee

Complaints are accepted formally or informally by any of the following methods:

• AC website

• Email

• Letter

• Phone call

4.7.2. Outside Complaints received by AWO Inspector

If the inspector receives a complaint from the public, state, or local counterpart, 

they will relay the information to their SACS.

If the SACS and inspector agree it warrants a formal complaint, and the 

complainant wishes to remain anonymous, the inspector:

• Will submit the complaint on their behalf by phone/email or by using the 

public-facing online complaint portal

• When submitting the complaint by email the inspector will include that the 

complaint was generated by a member of the public. Note: if the 

complainant wishes to track the complaint it must be submitted in writing 

(not anonymously).

If the generation of a formal complaint is not necessary, the issue may be 

evaluated during the next inspection.

If the complaint involves un-licensed/registered facilities, the AWO Search SOP 

may be initiated.

Inspectors should encourage all complainants to submit their complaint via email 

or the public website. However, the public is not required to use these methods 

to report a complaint. Reminder: informal/verbal complaints made by other 

entities will be accepted.
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4.7.3. Complaint Notification, Tasks, & Supervisor Discussion

Complaints will be categorized by Program Support as either Tier I, Tier II or Tier 

III. The inspector and SACS will receive notification by both email, and the 

inclusion of the complaint in their eFile “Inquiries Assigned to Me” list.

Questions about the complaint should be directed to the SACS.

After receiving notification of the complaint, the inspector will:

• Review the complaint within 10 days of receipt. If this deadline cannot be 

met, the inspector must notify their supervisor prior to the deadline.

• Discuss with their SACS (or SOTW or appropriate AD if SACS not available) all 

Tier I complaints or any complaint that they may need assistance with, and 

their plan to address the complaint

• NOTE: Inspectors employed with AC for 2 years or less must discuss Tier II 

complaints with their SACS.

• If necessary, reach out to a National Policy Staff Officer or Field Specialist for 

assistance in creating the plan, or for information on a particular species 

SACS (or SOTW or appropriate AD) will respond within 5 days to the inspector 

regarding the plan to address the complaint. If additional information becomes 

available regarding the complaint, the inspector will be informed, unless the 

information is restricted.

After the complaint has been addressed and the complaint response submitted 

to the supervisor for approval, the inspector will set the status of the “Complaint 

Assigned” eFile task to “completed”

4.7.4. Complaint Inspection & Closure

The inspector must follow up on all complaints by the Reply Due Date (45 days 

from notification). If this Due Date cannot be met, the inspector must notify 

their SACS as soon as possible so other arrangements can be made. 

Upon completion of the complaint inspection/investigation, the inspector must:

• Draft a formal complaint response

• Submit this first draft to their supervisor for review and approval. The 

method of submission is either by email or entering into the Results field in 

eFile.

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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• Change the complaint status to “Pending SACS Review”

• If edits are needed to the response, make the edits and resubmit the

response to their supervisor for final approval and change the complaint

status to “Pending SACS Review”

The SACS must:

• Review the complaint response, and any associated documents, for accuracy

and completeness

• If edits are needed, discuss the edits with the inspector who will make

necessary edits and change the complaint status to “Pending Inspector

Review”

• When the final response is agreed upon by the inspector and SACS, the SACS

will follow the procedure to close the complaint

• Review and approve all memos or supporting documentation. Internal

memos, or other supporting documents associated with complaints, will be

kept to a minimum and only used if necessary. NOTE: Memos must be sent

to the SACS for review prior to uploading into eFile.

NOTICE

For complaints involving birds at licensed facilities, inspector must 

note within the complaint response that birds are covered by the 

AWA, but no standards are being enforced at this time and 

document all observations made or actions taken (e.g., verifying 

veterinary care has been provided, advising the licensee that 

veterinary care was necessary, forwarding the information to state 

or local authorities, etc.). 
--- Animal Care Inspection Guide ---

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4.8. Courtesy Visits

Courtesy Visits are opportunities for Animal Care to provide learning 

opportunities and build relationships with facilities. 

4.8.1. 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

are compliant with the Regulations and Standards

• Facilities seeking to improve their understanding of the AWA requirements,

and to verify that improvements they are making put them in compliance

with the Regulations and 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 cannot be

performed in lieu of an inspection

Courtesy Visits should not influence or change the inspection or enforcement 

process at a facility. 

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 for guidance.

4.8.2. Documenting a Courtesy Visit

All Courtesy Visits, whether at regulated or non-regulated facilities, must be 

documented in eFile:

• If two or more employees are involved in the activity, only one employee will

make the entry into eFile

NOTICE

Courtesy Visits are not permitted after the 1st or 2nd licensing inspection.

Courtesy Visits are not permitted within 90 days of the expiration date of a 

current licensee’s license whether they have submitted their relicense 

application or not.
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• 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 ensure an applicant 

understands the Regulations and Standards and is prepared for the first 

Licensing Inspection. These are visits conducted prior to the first

Licensing Inspection.

2. 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 with the Regulations or Standards.

3. 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.

4. 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.

4.8.3. 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

NOTICE

If a “Direct” animal welfare problem(s) is identified during a Courtesy Visit at 

a facility that is not licensed or registered, the inspector must the contact 

their SACS for guidance. Options in these cases include, but are not limited 

to, contacting local law enforcement or State animal welfare organizations. 
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LICENSED/REGISTERED FACILITY

For a current licensee or registrant: 

• Prior to the courtesy visit, notify the licensee/registrant that if a direct noncompliance is identified during the courtesy visit it will be cited according to 

our current inspection procedures

• Offer to look at areas they are concerned about 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, cite the direct 

non-compliance on a focused inspection report, follow all inspection procedures 

described in Chapter 2 for direct citations, and inform the facility that an 

unannounced inspection will be conducted to follow-up on the direct 

noncompliance.
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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.

4.9.1. Dead Animal/Parts 

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.

4.9.2. 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.

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

4.11.1. 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.

4.11.2. 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

4.12.1. Conducting the Inspection

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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4.12.2. 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. 

4.12.3. 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:

• Caution signs, such as:

o Do not get out of car

o Do not put fingers in cages

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 Feeding only allowed when facility attendants are present

o Remove all objects from exterior of vehicle (flags, etc.)

• 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

• Number of employees/attendants at designated feeding stations and/or 

public feeding areas

• Monitoring of areas not readily visible to attendants

• Procedure in the event of an animal escape or attack

Unacceptable methods of handling at a drive-through park include:

• Housing non-compatible animals in the same area [3.133, 3.160]

• Feeding from personal vehicle with no or an insufficient number of 

attendants present to patrol, monitor, and intervene during such activities 

[2.131(c)(1), 2.131(d)(2)]

• Animal is able to put its head or other body parts inside privately-owned 

vehicle [2.131(c)(1), 2.131(d)(2)]

• Insufficient distance or barrier between animal and public [2.131(c)(1)]

4.12.4. Public Feeding

The public may not bring outside food into the facility for feeding of animals. 

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 an outside 

food source and what actions are taken if discovered by the facility.

Food offered to the animals must be:

• Wholesome

• Palatable

• Appropriate for the species

• 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 prevent 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
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• Video surveillance of the feeding area with radio dispatch 

• Distribution or posting 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

NOTE: Facility must have sufficient barrier, space, or attendant present during 

public feeding.

• Unacceptable practices with respect to feeding animals by the public: 

• Use of any of the following personal vehicles/situations [2.131(c )(1), 

2.131(d)(2)]

o Motorcycle

o Vehicle with open or soft roof, or with doors off

o Guests riding in back of open truck bed (personal vehicles)

• Physical contact/harassment of animals by public [2.131(b)(1)]

• Feeding food or other items not provided by facility [2.131(d)(4)]

• Animal is able to put its head or other body parts inside privately-owned 

vehicle [2.131(c)(1), 2.131(d)(2)]

• Feeding from personal vehicle with no attendants present, or insufficient 

number to patrol, monitor, and intervene during such activities [2.131(c)(1), 

2.131(d)(2)]

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. 

4.12.5. 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 

Separation of Businesses

Some drive-through zoos/parks also have other animal-related activities that are 
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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

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 

Access to Shelter

Adequate shelter is essential for all animals at all facility types. The large 

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
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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. 

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 

• Review the facility records for injuries, deaths, and animals provided 

veterinary care to help evaluate the impact of physical hazards

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)]. 

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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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?

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. 

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

• 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 
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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. 

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. 

4.13.1. 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.

4.14.1. 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.

4.14.2. 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

4.14.3. Space

Marine mammal primary enclosures must meet the space requirements in 

section 3.104.

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

4.14.4. 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

4.14.5. 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

4.14.6. 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.

4.14.7. 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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4.14.8. 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

4.14.9. 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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4.14.10. Contingency Plan for Water and Electric Power

In addition to the Contingency Plan required in Section 2.134, facilities must 

have a written contingency plan regarding emergency sources of water and 

electric power in the event of failure of the primary sources, when this failure 

could be detrimental to the health and well-being of the MM’s housed at the 

facility. 

The Contingency Plan must be in writing and approved by the AC Deputy 

Administrator. 

Contingency plans must include, but not be limited to:

• Specific animal evacuation plans in the event of a disaster

• Description of back-up systems and/or arrangements for relocating marine 

mammals requiring artificially cooled or heated water

• If the emergency contingency plan includes release of marine mammals, the 

plan must include provision for recall training and retrieval of such animals

Contingency plans should be sent by the facility to the Fort Collins AWO office 

for approval. 

If you have concerns that the Contingency Plan is out-of-date, discuss with your 

SACS. 

4.14.11. 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

4.14.12. 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. 

4.15.1. 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.

4.15.2. 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 correction date is given if an NCI is identified except for Directs as noted 

below

• If a Direct NCI is identified:

o Designate the NCI as a “Direct” and assign an appropriate correction 
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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

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.

4.16.1. 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 Pet birds

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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4.16.2. 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 and/or birds if applicable

• Health Certificates if applicable

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

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

4.16.3. 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

4.17.1. Inspection Procedures

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 

 

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 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.

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, or nests

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 

4.17.2. 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

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)
--- Animal Care Inspection Guide ---

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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.

4.18.1. Types of Photo Shoots

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

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

4.18.2. 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.
--- Animal Care Inspection Guide ---

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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. 

 

4.19.1. 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

4.19.2. First Prelicense Inspection

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 (with a maximum of 10 

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.

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 Field 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. 

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 and/or

birds)

- Must be in writing and accurately reflect the conditions at the facility

(Optional APHIS Form 7050 may be used for NHPs.)

- 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

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

4.19.3. 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 
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when he/she is ready (but within 60 days following the 1st PL inspection).

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

4.19.4. 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

4.19.5. Completing the Inspection Report

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 
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contact the USDA at 970-494-7478.” 

• 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

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: 

NOTICE

Do not designate any noncompliance as a Direct, Critical, or Repeat. 
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• Complete the Inspection Report citing all NCIs and cite 2.3(b) to indicate 

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: 

Deputy Administrator

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: 

Deputy Administrator

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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4.19.6. 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

4.19.7. 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

• For Directs cited on 1st or 2nd Relicense Inspection:

o A short correction date should be given if not a repeat. The following 

language should be used on the IR: “Correct by (date) or prior to your 

next schedule relicense inspection whichever comes first.” 

o Inform your SACS that a Direct was cited (phone, email, or text)

o If the next RL inspection is scheduled within a week:

- reinspect the Direct on that RL inspection

- After the inspection, notify your SACS that the Direct was corrected 

(or not). If corrected, note that on the RL inspection report. Also 

notify your SACS who will have an AD manually reset the RBIS to 

recognize that the Direct was corrected. 

- If not corrected, cite as a repeat and inform your SACS

o If the next RL inspection is not scheduled within a week:
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- conduct an unannounced, focused, reinspection no later than 14 days 

after the RL inspection to determine if the Direct has been corrected

- If corrected, note that on the inspection report 

- If not corrected, cite as a repeat

• For Directs cited on 3rd Relicense Inspections:

o A short correction date should be given if not a repeat

o Inform your SACS that a Direct was cited (phone, email, or text)

o If the current license has not expired, conduct an unannounced, focused, 

reinspection prior to the expiration of the license to determine if the Direct 

has been corrected

o If the current license has already expired, contact your SACS for further 

instructions

• For statements on the Inspection Report, see 4.19.7.1 Completion of the 

Relicensing Inspection Report

• 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.

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. 
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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: 

Deputy Administrator

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 “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.”

4.19.8. 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. Public Walk-In Aviary Inspection

4.20.1. Exterior Aviary Check & Entering

Before entering, walk around the outside of the aviary. Assess compliance by:

• Looking for any evidence of pests or predators

• Examining the sides of the enclosure for any holes, disrepair, or potential 

areas of escape or predator entrance

• Assessing for vegetation over-growth or clutter near the aviary

When entering the aviary:

• Look for and follow all biosecurity precautions such as hand-washing stations 

or foot baths 

• Evaluate the double-door entry system or any equivalent system in place to 

prevent the accidental escapes of the birds in the aviary 

• Ask the facility about any escapes that have happened since the last 

inspection

4.20.2. Inside the Aviary

Aviary Configuration and Safety

When assessing the safety of the aviary some key areas to consider include but 

are not limited to:

• Presence of defined pathways and handrails that limit public access

• Sufficient areas in the aviary where the birds can visually and/or physically 

retreat from visitors

• Are daily observations performed to quickly identify injured or sick birds and 

provide medical care

• Aquatic areas which are large enough to pose a drowning risk have 

preventative measures such as a netting, sloped edges, or objects in the 

water to allow birds to climb out

• Placement of perches, nests, enrichment items, food, or water receptacles 

are not within arm’s reach of the public. This includes ensuring food is not 

placed in public pathways.

• Are risky behaviors of birds and members of the public being monitored and 

discouraged. This includes interacting not under the direction and 

supervision of facility staff. Note: Birds may be more aggressive during 

breeding or nesting times.

• Are there signs/posted information notifying the public to watch for birds on 

the ground to avoid stepping on or otherwise injuring the birds, not to chase 

the birds, or when entering/exiting to watch for birds to minimize escapes.
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• For aviaries with free-flighted birds, the risk of collisions needs to be 

continuously evaluated and mitigated. This can include:

o Using materials that are obvious to birds in flight such as bird-safe glass 

or using materials that are pliable in case of collisions, such as mesh 

netting

o Use of acclimatization and conditioning for new bird introductions to the 

enclosure and minimizing significant changes to areas which could lead to 

collisions

o Providing a low-stress environment that minimizes birds getting easily 

frightened and frantically flying away. This involves having only 

compatible animals in the aviary and monitoring the public for unsafe 

behaviors such as chasing.

o Ensuring the birds are not overcrowded in the aviary

o Having adequate and appropriate lighting for birds to clearly see all 

obstacles

Environmental Conditions

Depending on the design, materials, or ventilation system, an aviary may have 

problems with high temperature and/or high humidity. Temperature, humidity, 

and ventilation need to be assessed for the bird’s comfort along with asking 

about how they maintain the aviary in all weather extremes. 

For indoor aviaries, ensure the opening of exterior doors do not cause significant 

temperature changes or drafts that affects the bird’s comfort.

If the aviary is an outdoor enclosure, shelter needs to be closely examined to 

determine if it is appropriate for the local climatic conditions to protect all birds 

from all adverse weather conditions. Shelters must be adequately ventilated, 

have shade, provide protection that comfortably contains all the birds at one 

time without causing intraspecific aggression or grouping of incompatible birds, 

and prevent their discomfort from direct sunlight, precipitation, or wind.

Assess drainage in aviary and ensure all birds have access to a dry area.

Observing the Birds

During the inspection, you should:

• Ask the facility how daily observations to assess the birds’ health are 

performed, including reclusive birds, birds on a nest, and chicks

• Visually inspect and count as many birds as possible. Look for long toenails, 

poor feathers, beak symmetry, obvious eye issues or injuries, evident 

respiratory issues, lameness or swelling of the feet, and adequate body 

condition. If you see any flight capable birds staying on the ground or any 

bird holding its wing in an abnormal position, ask the facility about the health 

status of that animal. For large aviaries, you should consider using 
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binoculars.

• Evaluate interactions between animals in the aviary. Look for signs of 

aggression and determine if the bird can easily get away. Signs of aggression 

can include raising the wings, loud vocalizations, biting, hissing, picking at 

another’s feathers or bald spots, dilating pupils, chasing the other bird 

around the enclosure, and preventing access to food or drinking water. Also 

look at non-avian animals possibly negatively impacting the birds.

Water and Food Sources

During the inspection:

• Visually inspect the placement and cleanliness of the water and food 

receptacles. Aviaries with multiple birds must have enough food and clean 

water sources for all animals. For flighted birds the receptacles should be 

elevated and easy for the birds to access. Aquatic areas should be assessed 

for appropriate sizing (including the dry area and proper slope into and out of 

the water), and for appropriate water quality (no trash or food waste 

present, and no excessive algal growth/turbidity, etc.).

• If food is placed directly on the ground, the floor must be dry, clean, and 

ensure the food is wholesome, palatable to the birds, and free of 

contamination or residual cleaning products. Assess the area for signs of 

pests.

• Assess all aquatic areas for potential entrances by predators and pests

Cleaning & Sanitization

All animals need to have access to a clean space (including perches), be free of 

excessive feces and food waste, and prevent accumulation of dirt and debris, 

and other disease hazards.

Water and food receptacles need to be clean and sanitized as often as necessary 

to prevent accumulation of dirt, debris, food waste, excreta, and other disease 

hazards.

Small or young aquatic avian species can become entrapped or drown during the 

emptying of aquatic pools. Evaluate the safety of the drainage system when 

these pools are cleaned. Mesh covers over drainage openings or low flow 

drainage can alleviate this risk.

Perches and Vegetation

During the inspection, you should:

• Ensure the aviary has plenty of perches for every bird and that the perches 

are an appropriate size, suitable materials, and in good repair

• Ask if the plants inside the enclosure have been determined to be safe for 

the animals inside the aviary. Look at any large trees or plants in order to 
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evaluate safety.

• For birds that may be stressed by human presence, verify there is an area for 

the birds to retreat (both visually and physically) from visitors

4.20.3. Public Feeding and Public Interaction

Determine if the facility is intentionally having the birds interact with the public. 

Some factors that indicate the facility is intentionally having the birds interact 

with the public include, but are limited to:

• Selling seed sticks or any other food items intended for the birds

• Birds are regularly landing on people or advertisements of the aviary include 

photos or videos of the public handling the birds

• Having perches, enrichment items, food, or water receptacles within in arms 

reach of the public

• Not monitoring or discouraging birds from interacting with the public if it 

does happen 

• No instructions or signs discouraging public interactions with the birds

For public interactions: If the facility has periods of public contact with the avian 

species or other covered animals in the aviary, the facility must:

• Follow the handling regulations (§ 2.131), including handling with minimal 

risk of harm to the animal and to the public with sufficient distance and/or 

barriers, and

• Having an identifiable attendant at all times that can monitor the activity

If you are able to view a public interaction on inspection, it’s highly encouraged.

4.20.4. Recordkeeping

During the inspection, you should:

• Ask about adverse incidents involving the birds or public since the last 

inspection

• Check records for significant number of deaths, deaths from trauma or 

aggression from other animals, or unexplained deaths. Deaths, injuries, and 

escapes need to be assessed for compliance.

• Check inventory numbers with what you saw on inspection. Refer to sections 

2.6.2.2 Difficult to Count Species and 2.6.2.3 Species/Circumstances where 

Accurate Counts are Impossible when inventory is not matching what was 

seen on inspection. 
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4.21. Search Inspection

A search is an inquiry relating to any person allegedly conducting regulated 

activity without a license or registration. 

4.21.1. 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

4.21.2. Sources of Information

Sources of information include, but are not limited to:

• Advertisements

• Animal protection groups

• Anonymous tips

• APHIS personnel

• City, county, or State agency

• Dog or exotic animal auction records

• General public

• Internet sites
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• 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

 

4.21.3. Information Follow-Up

If an inspector receives information regarding a person conducting regulated 

activity without a license or registration, they should:

• Confirm whether the person has an account in eFile

• If the person does not have an eFile account, provide all the relevant 

information (name, address, phone number, etc.) to PS to create an account

• Once the account is created, the inspector will create an eFile search inquiry

• Upload any documentation associated with the search allegations into eFile 

4.21.4. Preparing for the Search

Searches may be conducted in a variety of ways: 

• Facility Visit (preferred method) - Searches with animal welfare concerns 

must be conducted in person unless deemed unsafe after EMSSD 

consultation 

NOTE: The inspector may request a background check of the person by the 

EMSSD Security Branch. Contact your SACS. 

• By phone

• By email or internet search

Verify the information received by:

• Contacting the authorized representative

• Gathering additional information, such as:

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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o Newspaper or journal articles

o Classified ads

o Information off the internet

o Internet web site addresses

4.21.5. Conducting the Search

There is no firm completion deadline for searches. For searches with allegations 

of serious animal welfare concerns, the inspector should speak with their SACS 

to develop a plan/timeline for addressing the search. 

Regulated Activities NOT Confirmed 

If regulated activities are not being conducted or if there is uncertainty regarding 

the activity:

• Ensure the person understands what is considered regulated activity

• Provide an application and outreach materials (if needed), and 

• Instruct them to contact AC if their business activity changes or if they have 

any questions. 

Regulated Activities Confirmed 

If regulated activities are being conducted:

• Explain that a USDA license is required (continuing without a license / 

registration is a violation of the Animal Welfare Act), and 

• Provide an application and outreach materials (e.g., blue book, animal care 

aids, etc.) 

• Document all applications sent (in eFile). AWO may also request PS send an 

application packet and/or “We Believe Letter”. 

Facility with “Prior Documented Contact”

If AC has “Prior Documented Contact” with the subject of the search, the 

expectation is they are aware that conducting regulated activity without a 

license / registration is a violation of the AWA. They may be cited (via an 

inspection report). 

The following are considered “prior documented contact”: 

NOTICE

When regulated activity is alleged or suspected for previously licensed/

registered individuals or for an individual with previously confirmed regulated 

activity, conduct a search as soon as other priorities allow.
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• Prior licensure/registration/submitted application

• Previous “We Believe” Letter or application sent to the search subject 

(documented in eFile) 

• Prior search form with confirmation of regulated activity

• Prior documented discussion(s) with an AC employee regarding regulated 

activity 

Citing a Facility for Conducting Regulated Activity

If citing a facility for conducting regulated activity without a license/registration:

• Conduct an exit briefing to explain that a citation for conducting regulated 

activity without a license/registration will be written and issue a “Routine” 

inspection report citing Section 2.1(a)(1) [license], Section 2.30(a) [research 

registration], or Section 2.25(a) [transporter/intermediate handler 

registration]. This may be done in person or via telephone. 

• State “No regulated activities may be conducted until a USDA 

license/registration is obtained.” 

• Send the inspection report by regular and certified mail (with a return 

receipt), email, or deliver by hand (if safe to do so)

• Upload supporting documentation and photos with the inspection report 

Courtesy Visits

Courtesy Visits may be offered when contacting a facility for the first time

regarding regulated activity. The facility owner may decline, or the inspector may 

decide not to do a visit for safety reasons. 

4.21.6. Documenting Search Results in eFile

Inspectors must record all searches as an eFile Search Inquiry. 

NOTE: Each trace-forward/trace-back is documented as an individual search. 

4.21.7. Follow-Up Procedure

If regulated activity is confirmed during the initial search:

• follow-up searches should be done if regulated activity is suspected/reported 

again (create a new search inquiry)

• If regulated activity is again confirmed – cite as directed above (designate a 

repeat, if applicable), and

• Discuss next steps (e.g., CAS referral) with the SACS, or

• If no regulated activity is confirmed - no further action is needed
--- Animal Care Inspection Guide ---

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4.21.8. 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
--- Animal Care Inspection Guide ---

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4.22. Traveling Exhibitor Inspection

Each inspector should develop a consistent method of conducting inspections of 

traveling exhibitors that ensures a thorough and accurate inspection.

4.22.1. 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.”

4.22.2. 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 
--- Animal Care Inspection Guide ---

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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

4.22.3. 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.
--- Animal Care Inspection Guide ---

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4.22.4. 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, current 

enforcement actions, and contact information

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.
--- Animal Care Inspection Guide ---

Savedate 3/8/2024 12:55 PM Specific Types of Inspections 4-86 

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. 

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

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.
--- Animal Care Inspection Guide ---

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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.

Birds 

Ensure transportation enclosures that, at minimum, meet the individual specific 

space, safety, bedding, perch, and physical environment (including, but not 

limited to, temperature, humidity, sun and wind exposure) requirements for 

transport enclosures as specified in § 3.162.

Veterinary Care

When inspecting traveling exhibitors, check for the following:

• The exhibitor has an attending veterinarian
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• If the attending veterinarian is part-time, there is a formal arrangement

• Environmental enhancement plan for nonhuman primates and/or birds, 

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

• Health and well-being of the animals

• Health certificates, if required

• Required medical records for marine mammals

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

• Bird environmental enhancement plan

• Program of veterinary care appropriate for the animals being exhibited

• Water quality records for marine mammals

 

NOTICE

Copies of the original records are acceptable.
--- Animal Care Inspection Guide ---

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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

• 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.

4.22.5. 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 
--- Animal Care Inspection Guide ---

Savedate 3/8/2024 12:55 PM Specific Types of Inspections 4-90 

and food breaks for the drivers, handlers, and other people accompanying the 

animals is still considered “in transit.”

4.22.6. Animal Races

Examples of animals used for staged animal races include, but are not limited to:

• Camels

• 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

 

4.22.7. Animal Rides

See Animal Rides in this Chapter.

4.22.8. 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

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.
--- Animal Care Inspection Guide ---

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• 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

• 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

 

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.

NOTICE

Drugs may not be used to control the animals.

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.
--- Animal Care Inspection Guide ---

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• 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?

• 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 

 

4.22.9. Petting Zoos

See Petting Zoo Inspection. 

4.22.10. Photo Shoots

See Photo Shoot Inspection. 

4.22.11. 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 

NOTICE

Drugs may not be used to control the animals.

NOTICE

Never enter a pen or enclosure unless absolutely necessary and the animal(s) 

are secured.
--- Animal Care Inspection Guide ---

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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

4.22.12. Itinerary

All traveling exhibitors must submit an itinerary. For details, see Traveling 

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 ---

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4.23. 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

4.23.1. Licensing Requirements

Persons selling wild or exotic animals for covered purposes must be licensed.

Operators of the Auction

Operators of the wild/exotic animal auction must have a Class B license.

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. 
--- Animal Care Inspection Guide ---

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Never need a license May need a license Always need a license

Horses, donkeys, mules 

Reptiles

Farm-type animals used for 

agricultural purposes

Birds

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.

4.23.2. 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.

4.23.3. Inspection Procedures

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 
--- Animal Care Inspection Guide ---

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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

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. 

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 3/8/2024 12:55 PM Record-Keeping for Licensees 5-1 

Record-Keeping for Licensees

Contents

5.1. Records 5-2

5.1.1. Required Dealer and Exhibitor Records 5-2

5.1.2. Computerized Records for Dogs and Cats 5-3

5.1.3. Health Certificates for Dogs, Cats and Nonhuman Primates 5-3

5.1.4. Dealer and Exhibitor Records That Are Not Required 5-4

5.1.5. 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 3/8/2024 12:55 PM 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.

5.1.1. 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]

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]

For Nonhuman Primates (NHP)

For nonhuman primates, the following information is required:

• Environmental enhancement plan for nonhuman primates [3.81]

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)]

For Birds

For birds, the following information is required:

• Environmental enhancement plan for birds [3.154]
--- Animal Care Inspection Guide ---

Savedate 3/8/2024 12:55 PM Record-Keeping for Licensees 5-3 

5.1.2. 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)]

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).

5.1.3. 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. 
--- Animal Care Inspection Guide ---

Savedate 3/8/2024 12:55 PM Record-Keeping for Licensees 5-4 

 

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)]

5.1.4. 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

5.1.5. 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

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)]

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 3/8/2024 12:55 PM Record-Keeping for Licensees 5-5 

• 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 

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

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 3/8/2024 12:55 PM Record-Keeping for Licensees 5-6

• A description of each puppy, which includes the following.

o Breed

o Sex

o Color

o Distinctive markings

• Date of disposition, death, or euthanasia
--- Animal Care Inspection Guide ---

Savedate 3/8/2024 12:55 PM Veterinary Care Requirements for Licensees 6-1 

Veterinary Care Requirements for 

Licensees

Contents

6.1. Attending Veterinarian 6-2

6.1.1. Criteria 6-2

6.1.2. Multiple Attending Veterinarians 6-2

6.1.3. Veterinary Authority 6-3

6.1.4. Responsibilities 6-3

6.1.5. Health Certificates and Other Records that must be Prepared or Issued 

by Veterinarians 6-7

6.2. Written Program of Veterinary Care 6-8

6.2.1. Requirements for Dogs [3.13(a)] 6-8

6.2.2. Requirements for Animals Other than Dogs 6-9

6.3. Records 6-11

6.3.1. Required Records 6-11

6.3.2. Non-Required Information 6-14

6.3.3. Traveling Exhibitors 6-14

6.4. Inspection Guidance 6-15

6.4.1. General Information 6-15

6.4.2. Adequate Veterinary Care 6-15

6.4.3. Guidance for Communicating with the Attending Veterinarian 6-17

6.4.4. Recognition of Pain and/or Distress 6-19

6.4.5. Medication and Medical Supplies 6-22

6.4.6. Surgeries and Specialized Surgical Procedures 6-24

6.4.7. Euthanasia Guidance for Inspections 6-25

6.4.8. Additional Requirements for Inspecting Dogs 6-27

6.5. Documentation of Veterinary Care NCIs 6-29

6.5.1. Citing Section 2.40(b)(2) or 2.40(b)(3) 6-29

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 3/8/2024 12:55 PM 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

6.1.1. 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)]

6.1.2. 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 ---

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6.1.3. 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. 

6.1.4. 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

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)]
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• Exemption to the exercise requirement for a dog(s) [3.8(d)(1)]

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 ---

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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)].

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)]

Birds

Approval of the attending veterinarian is required for the following:

• Determines if a species-typical postural or social adjustments, such as dustbathing or foraging would be detrimental to the bird’s good health and wellbeing. [3.153(b)(1)]

• A species-appropriate plan for environment enhancement adequate to 

promote the psychological well-being of birds [3.154]

• Special considerations for birds requiring special attention, including 

[3.154(c)]:

o Nestlings, chicks, or fledglings
--- Animal Care Inspection Guide ---

Savedate 3/8/2024 12:55 PM Veterinary Care Requirements for Licensees 6-6

o Birds showing signs of psychological distress

o Birds used in research that require restricted activity

o Individually housed social birds that cannot see/hear their own or 

compatible species

• Birds must not be permitted to be maintained in restraint devices unless 

required for health reasons as determined by the attending veterinarian or 

by a research proposal approved by the IACUC at research facilities [3.154(d)]

• The attending veterinarian may exempt an individual bird from participation 

in the environment enhancement plan because of its health or condition, or 

in consideration of its well-being [3.154(e)]

• Birds must be fed at least once a day except as directed by the attending 

veterinarian, normal fasts, or other professionally accepted practices.

[3.155(a)]

• Potable water must be provided in sufficient quantity to every bird housed at 

the facility, unless restricted by the attending veterinarian [3.156]

• Socially dependent birds must be housed in social groups, except where the 

attending veterinarian exempts an individual bird because of its health or 

condition, or in consideration of its well-being, or for specific management 

needs, or where such social grouping is not in accordance with a research 

proposal and the proposal has been approved by the research facility IACUC

[3.160(a)]

• Birds that have or are suspected of having a contagious disease or 

communicable condition must be separated from healthy animals that are 

susceptible to the disease as directed by the attending veterinarian [3.160(c)]

• Carriers and intermediate handlers must not accept unweaned birds for 

transport unless transport instructions are specified and written by the 

attending veterinarian, and signed within 10 days of shipment [3.161(g)]

• All weaned birds must be offered food and potable water within 4 hours 

before being transported in commerce, unless the attending veterinarian 

approves a delay or unless a delay is in accordance with professionally 

accepted standards [3.164(a)]

• Dealers, exhibitors, research facilities, operators of auction sales, carriers,

and intermediate handlers must provide potable water to all live, weaned 

birds at least every 12 hours after accepting them for transportation in 

commerce, except for birds which, according to professionally accepted 

standards or under the direction of the attending veterinarian, require 

watering or feeding more or less frequently [3.164(b)]
--- Animal Care Inspection Guide ---

Savedate 3/8/2024 12:55 PM Veterinary Care Requirements for Licensees 6-7 

6.1.5. 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]:

• 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)]

• The attending veterinarian must execute temperature acclimation 

certificates for transport of unweaned birds [3.161(g)]

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.

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 3/8/2024 12:55 PM Veterinary Care Requirements for Licensees 6-8 

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)] 

6.2.1. 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 3/8/2024 12:55 PM Veterinary Care Requirements for Licensees 6-9

• Vaccinations for contagious and/or deadly disease of dogs in accordance with 

a schedule approved by the AV, and for adult dogs, in accordance with the 

manufacturer’s recommendations, including but not limited to:

o Rabies

o Parvovirus

o Distemper

Note: Vaccinations for puppies should follow the manufacturer’s 

recommendations but the schedule may be altered if deemed necessary by 

the AV.

• 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. 

6.2.2. Requirements for Animals Other than Dogs

The written program of veterinary care must: [2.40(a)(1)]

• Describe the facility's veterinary care plan
--- Animal Care Inspection Guide ---

Savedate 3/8/2024 12:55 PM Veterinary Care Requirements for Licensees 6-10 

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:

• 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

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 3/8/2024 12:55 PM Veterinary Care Requirements for Licensees 6-11

6.3. Records

6.3.1. 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.

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 ---

Savedate 3/8/2024 12:55 PM Veterinary Care Requirements for Licensees 6-12 

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)]

Cats

The following record requiring veterinary approval is required for cats, when 

applicable:

• Health certificate for transport [2.78(a)]

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)]

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.
--- Animal Care Inspection Guide ---

Savedate 3/8/2024 12:55 PM Veterinary Care Requirements for Licensees 6-13

[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
--- Animal Care Inspection Guide ---

Savedate 3/8/2024 12:55 PM Veterinary Care Requirements for Licensees 6-14 

• 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

Birds 

The following records requiring veterinary approval are required for birds, when 

applicable:

• Attending veterinarian approved EEP exemption [3.154]

• Written transport instructions by the AV for shipping unweaned birds 

[3.161(g)]

6.3.2. 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

6.3.3. 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.
--- Animal Care Inspection Guide ---

Savedate 3/8/2024 12:55 PM Veterinary Care Requirements for Licensees 6-15

6.4. Inspection Guidance

6.4.1. 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.

6.4.2. 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. 

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 
--- Animal Care Inspection Guide ---

Savedate 3/8/2024 12:55 PM Veterinary Care Requirements for Licensees 6-16

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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Savedate 3/8/2024 12:55 PM Veterinary Care Requirements for Licensees 6-17

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 

6.4.3. 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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Savedate 3/8/2024 12:55 PM Veterinary Care Requirements for Licensees 6-18

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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Savedate 3/8/2024 12:55 PM Veterinary Care Requirements for Licensees 6-19

• 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.

6.4.4. 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 Field

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)

Birds Typically stoic, birds may appear withdrawn, inactive, or 

isolating such as under the feeder or at the edges of the 

enclosure, less responsive to external stimuli, changes in 

“personality”/behavior, decreased appetite and weight loss, 

hunched posture where the neck is retracted towards the 

body with a fluffed out appearance of the feathers, the tail 

droop, tail may bob when the animal is at rest indicating 

increase in respiratory effort, eyes half opened or closed, dull 

feathers and a loss of interest to preen, a wing or foot held in 

a lower or abnormal position, small species struggle less and 

emit fewer distress calls than large species, increase in heart 

and respiratory rates.

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)
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Savedate 3/8/2024 12:55 PM Veterinary Care Requirements for Licensees 6-22

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.

6.4.5. Medication and Medical Supplies

The inspector must ensure that all medications and medical supplies at licensed 

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
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Savedate 3/8/2024 12:55 PM Veterinary Care Requirements for Licensees 6-23

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.

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 
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Savedate 3/8/2024 12:55 PM Veterinary Care Requirements for Licensees 6-24

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

6.4.6. 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
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Savedate 3/8/2024 12:55 PM Veterinary Care Requirements for Licensees 6-25

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

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

6.4.7. 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 
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Savedate 3/8/2024 12:55 PM Veterinary Care Requirements for Licensees 6-26

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. 

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)

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

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 
--- Animal Care Inspection Guide ---

Savedate 3/8/2024 12:55 PM Veterinary Care Requirements for Licensees 6-27 

consistent with the attending veterinarian's guidance. 

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

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

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) 

6.4.8. Additional Requirements for Inspecting Dogs

For all Routine Inspections, you, the inspector, should:

• Examine dogs according to the following criteria:
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Savedate 3/8/2024 12:55 PM Veterinary Care Requirements for Licensees 6-28 

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.

• 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.
--- Animal Care Inspection Guide ---

Savedate 3/8/2024 12:55 PM Veterinary Care Requirements for Licensees 6-29 

6.5. Documentation of Veterinary Care NCIs

6.5.1. Citing Section 2.40(b)(2) or 2.40(b)(3)

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.

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.
--- Animal Care Inspection Guide ---

Savedate 3/8/2024 12:55 PM Research Facility Inspection 7-1 

Research Facility Inspection

Contents

7.1. IACUC Review Information 7-3

7.1.1. General Information 7-3

7.1.2. Review of the Program of Humane Care and Use and Facility Inspection

7-5

7.1.3. Reports to the Institutional Official 7-6

7.1.4. Protocol Activity Suspension 7-7

7.1.5. Complaints or Concerns 7-8

7.1.6. Records 7-8

7.1.7. Significant Changes to Animal Activities 7-8

7.1.8. Telecommunications for IACUC Meetings 7-9

7.1.9. Information to Review 7-10

7.2. Protocol Review Information 7-11

7.2.1. Inspection Protocol Review Guidance 7-11

7.2.2. Sampling Guidance 7-11

7.2.3. Protocol Approval Process 7-13

7.2.4. Protocol Review 7-13

7.2.5. Specific Types of Protocols 7-16

7.2.6. Inspection Procedures 7-20

7.3. Veterinary Care Requirements for Dogs 7-23

7.3.1. Written Program of Veterinary Care [3.13(a)] 7-23

7.3.2. Medical Records for Dogs [3.13(b)] 7-24

7.4. Contracted Research or Projects that Involve Multiple Registrants 7-26

7.4.1. No Delegation of Responsibilities 7-26

7.4.2. Specific Responsibilities 7-26

7.4.3. All Responsibilities Designated 7-27

7.5. Records 7-28

7.5.1. Required Research Facility Records 7-28

7.5.2. Animal Records 7-28

7.5.3. Annual Report 7-29

7.5.4. Retention 7-33

7.5.5. Availability 7-33

7.5.6. Confidentiality and Removal of Records 7-33

7.6. Guidance for Veterinary Schools and Veterinary Technician Programs (VTP) 

for the Inspector 7-35

7.6.1. Teaching versus Research 7-35

7.6.2. Inspection Procedures 7-35

7.6.3. Special Considerations 7-36

7.7. Termination of a Registration 7-37

7.7.1. Conditions for Termination 7-37
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7.8. Holding Period 7-38

7.9. Research Facility Protocol Selection Worksheet 7-39

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 

7.1.1. General Information

All IACUC responsibilities, functions, and activities must be completely and 

thoroughly reviewed.

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

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

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.

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

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

7.1.2. 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)].

The IACUC may use subcommittees composed of at least two committee 

members and may also invite ad hoc consultants to assist in conducting the 

inspections. More than one subcommittee may be utilized, such that different 

subcommittees may inspect different areas of a research facility. However, both 

members of any subcommittee must each physically inspect, at least once every 

six months, all of their designated areas of the research facility’s animal facilities, 

including animal study areas. Although subcommittees may perform the 

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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inspections and conduct the program review, the subcommittee(s) must present 

their findings to a convened quorum of the IACUC for approval.

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

7.1.3. 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 

description and reason for the departure

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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• 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.

7.1.4. 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

o Informed the appropriate Animal Welfare Operations Office ofthe 

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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suspension, including a full explanation

o Informed other appropriate Federal funding agencies of the suspension

7.1.5. 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

7.1.6. 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

7.1.7. 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)

The following significant changes may be handled administratively according to 
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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.

7.1.8. 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 

manner that ensures an accurate count of the vote. A mail ballot or 
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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. 

7.1.9. 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

• Standard operating procedures
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7.2. Protocol Review Information

7.2.1. Inspection Protocol Review Guidance

Protocols and the IACUC approval and monitoring of protocols should be 

completely and thoroughly reviewed during an inspection.

7.2.2. 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.

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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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

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

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

7.2.3. 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. 

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

7.2.4. Protocol Review

General Protocol Requirements

A protocol to conduct an activity involving animals must be completely reviewed 

every 3 years by the IACUC and 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 and birds 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)]

7.2.5. Specific Types of Protocols

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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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

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

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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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

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
--- Animal Care Inspection Guide ---

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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

7.2.6. 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.
--- Animal Care Inspection Guide ---

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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
--- Animal Care Inspection Guide ---

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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

Birds Small species struggle less and emit fewer distress calls than large 

species, increase in heart and respiratory rates, crouched posture 

with closed or partially closed eyes and head drawn toward the 

body, “fluffed” appearance, may remain at the bottom of the cage

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.
--- Animal Care Inspection Guide ---

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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:
--- Animal Care Inspection Guide ---

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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.
--- Animal Care Inspection Guide ---

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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.

7.4.1. 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

7.4.2. 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
--- Animal Care Inspection Guide ---

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7.4.3. 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.
--- Animal Care Inspection Guide ---

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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].

7.5.1. Required Research Facility Records

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

7.5.2. 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 
--- Animal Care Inspection Guide ---

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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)]

• Birds:

o Environmental enhancement plan for birds [3.154]

7.5.3. 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:
--- Animal Care Inspection Guide ---

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• Laboratory rats and mice (genera Rattus and Mus) bred for use in research

• Reptiles, fish, or other mammals exempt from regulation under the AWA 

• 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, 
--- Animal Care Inspection Guide ---

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research, or surgery, but not yet used for such purposes.

All animals contained on the facility’s inventory on September 30 of the 

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

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.
--- Animal Care Inspection Guide ---

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• https://www.aphis.usda.gov/aphis/ourfocus/animalwelfare/SA_Obtain_Rese

arch_Facility_Annual_Report

• To submit an Annual Report online, go to: 

https://www.aphis.usda.gov/aphis/ourfocus/animalwelfare/SA_Obtain_Rese

arch_Facility_Annual_Report

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 Exemption of an individual bird from some or all of the environmental 

enhancement plan [3.154(e)]

o Approval for the delay in cleaning of a bird enclosure(s)

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]
--- Animal Care Inspection Guide ---

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• 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 

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

7.5.4. 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, which

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)].

7.5.5. 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

7.5.6. 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
--- Animal Care Inspection Guide ---

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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, 

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.

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.
--- Animal Care Inspection Guide ---

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7.6. Guidance for Veterinary Schools and Veterinary Technician Programs (VTP) for the 

Inspector

7.6.1. 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. 

7.6.2. 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.

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 ---

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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)].

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.

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.

7.6.3. 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 3/8/2024 12:55 PM Research Facility Inspection 7-37 

7.7. Termination of a Registration

A research facility may no longer request to be placed on Inactive status. A 

research facility will either be registered or unregistered.

7.7.1. Conditions for Termination

A research facility’s registration will no longer be valid if the research facility: 

• Voluntarily requests registration termination. RF may submit an APHIS Form

7033 or a written request to the Deputy Administrator. 

• Fails to file an Annual Report of animal use to Animal Care for 2 consecutive 

years

• Goes out of business or ceases to function as a research facility

• Changes its method of operation so that it no longer uses, handles, or 

transports regulated animals, and does not plan to use, handle, or transport

regulated animals for a period of at least 2 consecutive years

A terminated research facility must file an Annual Report through the end of the 

fiscal year of its cancellation. 

NOTICE

A terminated research facility must notify AC, in writing, at least 10 days prior 

to using, handling, or transporting regulated animals again. [2.30(c)(2)]
--- Animal Care Inspection Guide ---

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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 ---

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7.9. Research Facility Protocol Selection Worksheet
--- Animal Care Inspection Guide ---

Savedate 3/8/2024 12:55 PM Confiscation Guidance 8-1 

Confiscation Guidance

Contents 

8.1. 8.1Criteria for Confiscation 8-3

8.1.1. Veterinary Care Issues 8-3

8.1.2. Shelter/Housing Issues 8-7

8.1.3. Husbandry/Cleaning/Sanitation 8-8

8.1.4. Ventilation/Air Quality 8-10

8.1.5. Separation/Behavior 8-10

8.1.6. Feed/Water 8-11

8.1.7. Handling 8-12

8.2. Documentation 8-14

8.2.1. Document all non-compliant items with photos and/or videos 8-14

8.3. Body Condition and Age Assessment Charts 8-17

8.3.1. Tiger Body Assessment Chart 8-18

8.3.2. Lion Body Assessment Chart 8-20

8.3.3. Leopard Body Assessment Chart 8-22

8.3.4. Cougar/Puma/Mountain Lion Body Assessment Chart 8-24

8.3.5. Elephant Body Assessment Chart 8-25

8.3.6. Body Condition Chart for Cats 8-26

8.3.7. Body Condition Chart for Dogs 8-27

8.3.8. Tiger Cub Size Information 8-29

8.4. Guidelines and Responsibilities for the Confiscation of Animals 8-30

8.4.1. AC Inspector Responsibilities 8-30

8.4.2. Suggested Go-Kit Checklist When Performing a Confiscation 8-31

8.4.3. SACS Responsibilities 8-32

8.4.4. AWO Management Responsibilities 8-33

8.4.5. Confiscation Timeliness 8-35

8.4.6. Responsible Person is Unavailable 8-35

8.4.7. IES Responsibilities 8-35

8.4.8. EMSSD Responsibilities 8-35

8.4.9. Safety Officer 8-35

8.4.10. Logistics Officer (if utilized) 8-37

8.5. Sample Documents 8-41

The purpose of this Chapter is to provide guidance for the units involved in 

confiscations.
--- 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.

WARNING

Some of the photographs of animals in severe physical conditions in this Section may be 

disturbing.
--- Animal Care Inspection Guide ---

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8.1. 8.1Criteria for Confiscation

During the inspection process when an animal is determined to be in a state 

of suffering by the APHIS official e.g.: Veterinary Medical Officer or Animal 

Care Inspector, and relief is not provided by the facility, and there is no 

evidence relief will be provided in the immediate future, confiscation should 

be considered.

Animals are deemed to be in a state of unrelieved suffering when they are 

forced to endure conditions, arising out of the licensee’s failure to comply 

with regulations promulgated under the Animal Welfare Act (AWA), which 

causes severe pain or distress, severe discomfort, or which could directly 

and negatively impact the health and well-being of the animal if immediate 

actions are not taken by the licensee to remedy the situation. 

Examples of conditions that may cause suffering include but are not limited 

to: animals with serious medical problems that are not receiving adequate 

veterinary care; animals without adequate food or water; animals exposed 

to temperature extremes without adequate shelter or bedding; and animals 

held in unsanitary enclosures. Animals do not need to be in jeopardy of 

dying to be in a state of unrelieved suffering. Veterinary Medical Officers 

(VMO) are legally qualified to determine whether an animal is suffering.

There are some conditions that if allowed to worsen, may contribute to a 

situation that results in a confiscation. 

The following information pertains to situations where confiscation should 

be considered.

 

8.1.1. Veterinary Care Issues 

Veterinary care issues are a source of chronic or acute suffering for the 

animals inspected. These include:

• General conditions

o Animals are severely malnourished and/or emaciated with no 

veterinary assessment

o Animals are severely lethargic with no veterinary assessment

o Animals are observed to have chronic, untreated intestinal issues

NOTICE

Citations listed are examples only. The specific citation will be 

dependent on the situation and should be discussed with your 

supervisor.
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o Animals are found to be dead, dying, or in overall poor health

• Infectious disease processes in which the animal is suffering or 

distressed and without veterinary assessment or treatment

• Trauma/injuries/untreated problems in which the animal is suffering, 

such as, but not limited to:

o Fractures or open wounds

o Severe chronic skin or eye issues

o Severe chronic dental issues 

o Skin ulcerations or sunburn

o Animals are found with severely matted hair causing significant skin 

problems

o Foot or hoof foreign bodies

o Halters, collars and other restraint devices that are too tight or 

poorly fitted and are causing injury to the animals, especially those 

permanently left on the animals 

Certain husbandry requirements may become veterinary care issues that 

lead to unrelieved suffering:

o Heavy unshorn coats 

Sheep/certain goats/ llamas/alpacas, if not sheared for an extended 

period of time, can be in a chronic state of suffering. This is especially 

true in warm weather. This may also apply to long-haired breeds of 

dogs, cats, and other species. Coats which remain unshorn for long 

periods of time may become infested with maggots or cause chronic 

skin irritation. 

8-1. Sheep suffering from unshorn coat in hot weather - this sheep had not been 

shorn in five years 2.40(b)(2), 2.131(b)(1).

o Hoof/Nail Care

Untrimmed nails or hooves that are causing lameness and/or 

locomotion difficulties may also contribute to joint pain and arthritis 

later in life. Large ungulates, such as giraffe, may suffer chronic, 

painful joint issues even if their hooves are only slightly overgrown. 
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8-2. Overgrown llama nails 8-3. Overgrown miniature zebu hooves

8-4. Overgrown giraffe hooves 2.40(b)(2)

Sample pictures of vet care issues to be considered for 

confiscation

8.1.1.1.1 Emaciation or evidence of malnourishment

8-5. Emaciated Asian Elephant
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8-6. Emaciated Lion

8-7. Thin tiger with chronic poor hair coat

8-8. Emaciated dog, dorsal view

2.40; 3.129(a) (Subpart F animals); 3.9(a) (dogs)

5.1.1.1.1 Untreated veterinary problems

8-9. Chronic untreated eye problems 8-10. Chronic untreated eye problems 2.40 

8-11. Serious untreated tail injury of cougar 8-12. Ruptured abscess on dog
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8-13. Bloody feces 8-14. Overgrown hooves

8-15. Dead dog in enclosure 8-16. Mutilated front leg of dog

8-17. Untreated skin problems causing 

pain/discomfort 2.40

8.1.2. Shelter/Housing Issues 

Below are shelter/housing issues that may support confiscation:

• Lack of shelter in cold weather, if animals appear to be shivering or 

showing other signs of severe discomfort from the cold

• Lack of shade in hot weather, if animals are showing signs of severe 

discomfort such as panting, heat stress, etc.

• Lack of shade in bright conditions causing animals to squint or have 

chronic eye discomfort

• Shelter provided is too small and/or does not allow access for all animals 

during inclement weather, and animals are showing clear signs of severe 

stress or discomfort

• Insufficient bedding for temperatures below 50 degrees Fahrenheit and 
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the animals are showing clear signs of severe stress or discomfort 

(shivering, huddled in corners, etc.)

• Enclosures are extremely wet or covered with excessive accumulations 

of feces, causing discomfort or medical issues

8.1.3. Husbandry/Cleaning/Sanitation 

Below are husbandry/cleaning/sanitation issues that may support 

confiscation:

• Accumulated feces and waste inside the shelter such that animals 

cannot avoid contact with it and are showing signs of severe distress, 

discomfort, or clinical manifestations of disease

• Accumulated wet and/or dirty bedding within the shelter that is 

affecting the health and welfare of the animals

• Severe pest infestation that impacts the animals’ health 

• Unclean and/or unsanitary water and food receptacles that affects the 

health of the animal

• Poor ventilation and air quality

• Enclosures maintained such that animals cannot avoid unsanitary 

conditions. This can be a combination of feces, water, mud or other filth 

such as rotted foodstuffs. This can create a chronic pattern of suffering 

for animals trapped in such enclosures.

Sample pictures of shelter/housing/husbandry/cleaning issues to 

be considered for confiscation associated with environmental and/or 

other conditions

8-18. Elephant Chained with no access to shade 

3.127(a)

8-19. Inadequate sized shelter for four wolves

3.127(b)
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8-20. Shelter (dog) not structurally sound 3.1(a)

8-21. No bedding, rusted dog enclosure 

3.1(c)(1)(i); 3.3(a)

8-22. Dogs with no shelter or shade 3.4(b); 

3.6(a)(2)(vii) 8-23. Dogs with no shade 3.4(b); 3.6(a)(2)(vii)

8-24. Grossly inadequate space for lion (Lion is 

never moved out of cage for exercise) 3.128

8-25. Grossly inadequate space two tiger cubs 

3.128

8-26. Extremely soiled, overcrowded hamster 

enclosure 3.28(b)(1);3.28(b)(3)(iii); 3.31(a)(1)

8-27. Extremely soiled rabbit enclosure 

3.56(a)(1)
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8-28. Excessive accumulation of dog feces 3.11(a) 8-29. Layers of moist, filthy bedding 3.131(a)

8-30. Guinea pigs in unsanitary conditions 3.31(a)

8-31. Filth in an animal enclosure 3.11(a) (dogs); 

3.131(a)

8.1.4. Ventilation/Air Quality 

Confiscation is appropriate when non-compliances involving animals with 

unrelieved suffering or distress due to ventilation/air quality are identified. 

High ammonia levels can lead to acute discomfort of the respiratory tract 

and mucous membranes. Exposure to elevated ammonia levels in the air 

may also result in adverse long term animal health outcomes, 

including immunosuppression, chronic respiratory disease, and decreased 

growth rates and reproductive abnormalities in a number of regulated 

species. A determination of whether ammonia levels are too high is based 

on the presence of noxious fumes (e.g., your eyes burn) at the level of the 

animal’s eyes and nose. Since ventilation non-compliances cannot typically 

be photographed, document the animal’s clinical signs of suffering such as 

squinting, conjunctivitis, watery eyes, coughing, sneezing, etc. Also 

document any similar clinical signs experienced by the ACI/VMO. If two 

Animal Care veterinarians state that one or more clinical signs were 

observed, along with the description of the smell and human discomfort, 

confiscation may be considered. 

8.1.5. Separation/Behavior

Incompatible animals should not be housed together. Confiscation should 

be considered if animals are: 
--- Animal Care Inspection Guide ---

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• Housed in incompatible groups exhibited through clear signs of distress 

and/or physical injury

• Constantly under threat or stress from other animals, whether in the 

same or adjoining enclosures, such that there are clear signs of suffering. 

Severe stress levels can result in death of animals. 

Example: A wallaby penned between two tigers at one facility collapsed and 

died from the stress. Before it died, it spent all of its time tucked tightly in 

the one corner as far as it could get from the tigers. The cage bars were 

hardly adequate separation in this case.

8.1.6. Feed/Water

Below are feed/water issues that may support confiscation.

• No food or water is available, and the animals are noticeably 

underweight, dehydrated, showing clear signs of distress, or are 

exhibiting gastrointestinal disorders (chronic diarrhea) 

• Food/water is contaminated such that animal health is severely 

impacted

• Water and food receptacles are not being kept clean and sanitized, and

animal health is severely impacted by this

• Insufficient and/or poor-quality food is fed such that animals are 

displaying nutritional deficiencies or chronic intestinal problems

• Inappropriate diet for the species such that animals are exhibiting 

associated clinical signs such that animal health is severely impacted

• Improperly stored feed that is unsafe for the animals or is contaminated, 

decomposing or deteriorated to the point of being nutritionally 

inadequate or inedible

Feeding practices which may cause serious, life-threatening harm to the 

animals: 

• Chronic insufficiency of feed; or 

• Providing food that is inappropriate for the species, such as feeding dog 

food to any species of cat

Watering practices which may cause serious, life-threatening harm to the 

animals:

• Inadequate water

• Poor quality water may create chronic health problems such as internal 

parasite loads, giardiasis, bacterial or fungal infections

• Standing water may harbor disease-carrying insects such as mosquitoes
--- Animal Care Inspection Guide ---

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Photos

The photos below are not stand-alone reasons to confiscate but may help to 

document a pattern of suffering. 

8-32. Evidence of inadequate water (this bucket is 

bone-dry). The licensee stated the bucket had been 

filled that morning. The bucket was filled with water 

and the animals were noted to rush over and drank 

continuously for over 2 minutes (captured with video). 

3.10(a) (dogs); 3.130 (Subpart F animals) 8-33. Poor quality rotting chicken 3.129(a)

8-34. Rotting carcass in cougar enclosure 3.131(a); 

3.125(d) 8-35. Poor quality chicken and meat 3.129(a)

8-36. Self-feeder with moldy food 3.9(a)

8-37. Unsanitary water receptacles 3.10(a); 

3.10(c) (dogs); 3.130 (Subpart F animals)

8.1.7. Handling

Below are handling issues that may support confiscation.

• Licensee, and/or carriers and intermediate handlers, is not physically able to 
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care for the animals and has no trained personnel available to provide the 

required handling, husbandry and care. The animals are showing signs of 

severe suffering. 

• Licensee, and/or carriers and intermediate handlers, does not have appropriate 

experience to care for the species they have, and the animals are either 

showing signs of suffering, or in a situation that could be dangerous to the 

animals or to people 

• Licensee, and/or carriers and intermediate handlers, is observed abusing or 

mistreating the animals

• Licensee, and/or carriers and intermediate handlers, knowingly fails to provide 

adequate care for the animals

• Licensee, and/or carriers and intermediate handler, handles animals in a manner 

that endangers the lives of the animals or the public
--- Animal Care Inspection Guide ---

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8.2. Documentation

8.2.1. Document all non-compliant items with photos and/or videos 

Accurate and thorough documentation is critical to the confiscation process. 

Detailed write-ups, photographs, and videos all help to convey the severity of 

the situation and demonstrate the unrelieved suffering of the animals. Proper 

documentation is also necessary to clearly identify which specific animals are 

being considered for confiscation.

The write-ups should be clear, concise, and accurately identify the animals. 

Provide as much detail as possible including the species, physical description, 

age, sex, and identifying marks so that the animals can be clearly identified. Also 

include a detailed description of any environmental conditions that are of 

concern. Be sure to include any pertinent information from verbal exchanges 

with the licensee, and/or carriers and intermediate handlers. Photographs and 

videos should be clear and demonstrate the condition(s) prompting 

consideration of confiscation. When possible, include both the animal and the 

condition in a single photograph/video so that the viewer has no doubt of what 

is being conveyed. 

Photographs/videos should: 

• Be taken before and during the confiscation 

• Accurately and clearly depict the noncompliant items as well as the specific 

animals of concern, including ID (use photos in this document as examples) 

• Be accurately labeled with a description that is complete and detailed in 

order to prompt your memory should you be asked to testify about the 

inspection/confiscation years after the fact

Use videos to depict things that cannot be ascertained from photographs, such 

as the extreme thirst of an animal – example: video of animal drinking for 2 

minutes straight.
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8-38. 2.40(b)(3)

8.2.1.2 Taking meaningful photographs.

Make every effort to take a photo and/or video with the animal of concern in 

the same photo or video with the noncompliant item/issue.

8-39. 3.127(a); 3.127(b) Example of photo with animal in question and instrument 

measurements in the same photo.

If the issue includes documenting the weight of the animal, a good side view 

(lateral), a view of the animal’s back, either from the front or rear of the animal, 

and a photo from above the animal looking down (dorsal view) are most useful. 

Examples of photos of big cats with several views to accurately depict the 

weight of the animal
--- Animal Care Inspection Guide ---

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8-40. View down spine showing thin body 

condition

8-41. Side view (lateral) to evaluate ribs 

and spine

8-42. Dorsal view of cougar showing ribs 

and vertebrae

8-43. Lateral view of thin lion 

For more examples of documenting the weight of big cats, please review the 

body condition assessment chart photos 
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8.3. Body Condition and Age Assessment Charts

These charts may be used to help inspectors identify animals in critical or nearcritical condition, which if not addressed, could trigger a confiscation. 

Included are: 

• Tiger

• Lion

• Leopard

• Cougar

• Elephant

• Cat

• Dog

• Tiger Cub Weight Information Chart
--- Animal Care Inspection Guide ---

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8.3.1. Tiger Body Assessment Chart

1. Emaciated 

All ribs and vertebral 

bodies prominently 

showing, skin laying over 

hips and femur 

2. Underweight 

Ribs, vertebral bodies and 

hips slightly showing, 

“tucked up” appearance

3. Optimal body weight 

Hint of ribs and vertebral 

bodies

4. Overweight

No hips or ribs showing, 

rotund appearance to 

abdomen

5. Obese

Abdomen sagging, 

obvious fat over hips and 

shoulders 

Examples

8-44. Emaciated 8-45. Underweight
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8-46. Optimal body weight 8-47. Overweight

8-48. Obese
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8.3.2. Lion Body Assessment Chart

1. Emaciated. All ribs 

and vertebral bodies 

prominently showing, 

skin laying over hips 

and femur 

2. Underweight. Ribs, 

vertebral bodies and 

hips clearly showing

3. Optimal body weight.

Hint of ribs and 

vertebral bodies

4. Overweight. No hips 

or ribs showing, 

rotund appearance to 

abdomen

5. Obese. Belly dragging, 

obvious fat over hips 

and shoulders

Examples

8-49. Emaciated 8-50. Underweight
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8-51. Optimal weight

8-52. Overweight

8-53. Obese
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8.3.3. Leopard Body Assessment Chart

1. Emaciated 

All ribs and vertebral 

bodies prominently 

showing, skin laying 

over hips and femur 

2. Underweight 

Ribs, vertebral bodies 

and hips slightly showing, 

“tucked up” appearance

3. Optimal body weight 

Hint of ribs and vertebral 

bodies

4. Overweight

No hips or ribs showing, 

rotund appearance to 

abdomen

5. Obese

Abdomen sagging, 

obvious fat over hips 

and shoulders 

Examples

8-54. Emaciated 8-55. Underweight
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8-56. Optimal weight

8-57. Overweight

8-58. Obese
--- Animal Care Inspection Guide ---

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8.3.4. Cougar/Puma/Mountain Lion Body Assessment Chart

1. Emaciated 

All ribs and vertebral 

bodies prominently 

showing, skin laying over 

hips and femur. This 

animal cannot afford to 

lose any more weight

2. Underweight 

Ribs, vertebral bodies 

and hips clearly showing

3. Optimal body weight 

Hint of vertebral bodies, 

points of hips, and ribs 

showing

4. Overweight

Overweight cougars will 

have no hips or ribs 

showing and a rotund

appearance to abdomen

5. Obese

Pendulous abdomen, 

obvious fat over hips and 

shoulders
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8.3.5. Elephant Body Assessment Chart

1. Emaciated 

All ribs and vertebral 

bodies prominently 

showing, Underweight 

Ribs, vertebral bodies, 

and hips clearly showing 

skin laying over hips, 

femur, humerus and 

scapula. This animal 

cannot afford to lose any 

more weight

2. Underweight 

Ribs, vertebral bodies, 

scapula, and hips clearly 

showing

3. Optimal body weight 

Slightly round 

appearance, hips showing 

slightly

4. Overweight

Overweight elephants will 

have no hips or ribs 

showing

5. Obese

Pendulous abdomen, 

rotund appearance with 

no hips and a rotund 

appearance to abdomen
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8.3.6. Body Condition Chart for Cats

1. Emaciated 

Ribs, lumbar vertebrae, 

pelvic bones and all body 

prominences evident 

from a distance. No 

discernible body fat. 

Obvious absence of 

muscle mass.

2. 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.

3. Optimal body weight 

Ribs palpable without 

excess fat covering. 

Abdomen tucked up 

when viewed from side.

4. Overweight 

General fleshy 

appearance. Ribs 

palpable with difficulty. 

Noticeable fat deposits 

over lumbar spine and tail 

base. Abdominal tuck 

may be absent.

5. 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 ---

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8.3.7. Body Condition Chart for Dogs

1. 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.

2. 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.

3. 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.

4. 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.

5. Obese 

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.

--- Animal Care Inspection Guide ---

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8.3.8. Tiger Cub Size Information

Generic “Bengal” tiger cub weights are listed below. 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

AGE WEIGHT 6 weeks 12 - 15 lbs.

Birth 

weight

about 2.5 -

3.5 pounds

7 weeks 14 - 17 lbs.

1 week 4.5 - 6 lbs. 8 weeks 16 - 19 lbs.

2 weeks 6. - 7.5 lbs. 10 weeks 19 - 25 lbs.

3 weeks 7.5 - 9 lbs. 12 weeks 24 - 40 lbs.

4 weeks 9 - 10 lbs. 16 weeks 35 - 50 lbs.

5 weeks 10 - 12 lbs. 20 weeks 55 - 68 lbs.

8-59. 6-week-old Siberian tiger

8-60. 8-week-old Siberian tiger (14 

pounds)

8-61. 11-week-old “generic” Bengal tiger cub (21.5 

pounds)

8-62. 17-week-old generic “Bengal” white 

tiger cub (approx. 45 pounds)
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8.4. Guidelines and Responsibilities for the Confiscation of Animals

8.4.1. AC Inspector Responsibilities

• During an inspection, promptly recognize animal suffering and initiate 

confiscation procedures in accordance with the regulations and resource 

material

• Immediately involve and coordinate all on-site efforts with your supervisory 

animal care specialist (SACS)

• Clearly communicate to the dealer, exhibitor, intermediate handler, or 

carrier, verbally and in writing, all conditions that are causing animal 

suffering and the actions necessary for providing relief of that suffering. This 

includes writing a detailed inspection report which includes the following: 

1. Number and species of animal(s) found to be suffering and the individual 

identification numbers (for dogs or cats); also include the name of the 

animal (if verifiable), and/or a brief description of each animal, and/or 

the location of each animal (i.e., provide as much descriptive information 

as you can)

2. Identification of non-compliances or conditions causing the suffering

3. Steps that must be taken to correct the problem and alleviate the

suffering, e.g., examination and treatment by a qualified veterinarian

4. The time period in which the condition must be corrected so the animal is 

given relief and adequate care. This time period must be as soon as 

possible after determining the animal is suffering, but typically no more 

than 24 hours

• Take good photographs and videos of the involved animals and conditions

o Take videos of lameness or neurologic problems, if possible

o Take videos of thirsty animals drinking when offered water. It may be of 

benefit to take a longer video to demonstrate how long the animal drinks 

when offered water. 

o Take videos of animals demonstrating incompatibility 

• Keep the SACS informed of the situation and current on all pertinent facts 

and issues. This includes providing inspection reports, photographs, videos, 

and other relevant documents.

• When discussing the situation with licensees, and/or carriers and 

intermediate handlers, be clear about what can and cannot be agreed upon 

prior to the actual confiscation or voluntary relinquishing of the animals. If 

you are unsure about this, contact your SACS. Any agreements should be put 

in writing and signed by the responsible facility representative.

• If the suffering animal subject to confiscation is an endangered species or a 

marine mammal, notify Animal Welfare Operations (AWO) Management, 
--- Animal Care Inspection Guide ---

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who will then ensure coordination with appropriate government agencies.

• Consider weather conditions and have available a tarp/canopy for shelter, 

tables, and chairs and other equipment as needed during the actual 

confiscation or in the staging area.

8.4.2. Suggested Go-Kit Checklist When Performing a Confiscation

Communication and Technology

 Laptop computer/iPad

 Smart phone (tethering capable), hands-free set

 Power cords for laptop and phone (AC/DC and for tethering), extension cord

 Camera, charger, batteries

 Kestrel or IR gun as required

 Written phone directory/key contacts (AWO, HQ, ER, State, other)

 Battery operated work light, flashlight, and/or headlamp

 Radio (handheld and/or vehicle mounted base station if required)

 GPS 

 Binoculars if necessary

Apparel

 Weather appropriate apparel

 Gloves, work boots

 PPE as appropriate

Miscellaneous:

 Basic office supplies: Notebook, note pads, pens, tape, binder clips, paper 

clips

 Forms: All appropriate Letters/Forms in digital and print, USDA letterhead, 

other

 Business cards

 Camp chair, umbrella

Personal Items

 Personal cellular phone for backup or emergency communication

 Sunscreen, hand sanitizer, hand lotion, tissues, etc.

 Prescription and nonprescription medications

 Snack food, emergency food, and water/beverages

 Sunglasses, reading glasses, lens cleaners, etc.

 Coffee cup, paper towels
--- Animal Care Inspection Guide ---

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8.4.3. SACS Responsibilities

• Ensure all inspection resources needed for the confiscation are assigned and 

present. If the confiscation involves (nonhuman primates) NHPs, wild/ exotic 

species, and/or marine mammals, try to arrange for Field Specialists to be 

present or available for consultation. 

• Work with the assigned inspector and the AWO Office (the Director and/or 

Assistant Director) to ensure that suitable location(s) for the confiscated 

animal(s) are lined up.

• On site responsibility for:

o Operational decisions involving the confiscation, including but not limited 

to, ensuring Emergency Management, Safety, and Security Division 

(EMSSD) has set up appropriate security, issuing Notice of Intent to 

Confiscate (NOIC) and Notice of Confiscation (NOC) if applicable

o Ensure a Safety Officer is assigned and present on site

- The Safety Officer may be:

1) An employee who is trained to be a safety officer; 

2) If 1 unavailable, a member of the S&H Committee; 

3) If 1 and 2 are unavailable, an employee with prior experience as a 

Safety Officer

(See Safety Officer Job Aid below)

- Ensure inspectors conduct themselves professionally

- Based on size and complexity of confiscation, ensure a Logistics 

Officer (see Logistics Job Aid below) is assigned and present on site

- Assume all responsibilities not delegated

- Address any media situations 

- Ensure good communication and coordination with State or local 

officials with animal welfare responsibility at the facility 

- Consider a temporary staging area to triage and process large 

numbers of animals

• Coordinate with APHIS Investigation and Enforcement Services (IES)

o Work with AWO Management and IES leadership to determine the 

specific role of IES in supporting the investigation process and their 

location within the team structure

• With AWO Management, engage local and State agencies, and 

nongovernmental organizations as appropriate

o State or local agencies may be engaged for their authorities or 

capabilities
--- Animal Care Inspection Guide ---

Savedate 3/8/2024 12:55 PM Confiscation Guidance 8-33 

o Animal welfare organizations or local animal control agencies/shelters 

are commonly utilized to assist in confiscation operations

o Clearly communicated expectations pertaining to mission, objectives, 

public information, and behavior are essential

o Animal welfare agencies and organizations typically serve in the following 

roles:

- Assist with removal of animals from the site

- Receiving ownership of the animals from USDA 

- Provide care, adoptive homes, or other appropriate disposition for 

animals

• Authorize transfer of animals from USDA custody to animal control or 

sheltering partners

• Authorize euthanasia of animals as appropriate 

• Serve as onsite point of contact for media in close coordination with AWO 

Management and APHIS Legislative and Public Affairs

• Supervise transition to off-site operations 

o Confiscation Team continues to manage animals or track progress of 

those who have received animals from USDA

o Off-site operations could be located in a hotel, conference room, or any 

reasonable secure location

• Make sure cell phone is functional to answer calls from AWO Management, 

as well as to keep AWO Management regularly apprised of the status of the 

confiscation

• Based on what is happening at the facility, notify AWO Management of any 

site concerns and/or changes in procedures

8.4.4. AWO Management Responsibilities

• Notify IES and EMSSD as early as possible about a potential confiscation

Critical Issue

The SACS, inspector of record for the facility, and inspection team who have 

identified the need for a potential confiscation action are critical to the 

success of the team. The Inspection Team should transition into the 

Confiscation Team seamlessly. The SACS would typically transition to 

become the Confiscation Team Leader, with guidance from AWO 

Management. The inspector(s), with knowledge of facility history and 

personnel should be actively providing their knowledge and insight to help 

ensure a safe and efficient operation. SACS must ensure that this transition is 

effective and well-communicated to all confiscation personnel. 
--- Animal Care Inspection Guide ---

Savedate 3/8/2024 12:55 PM Confiscation Guidance 8-34

• Promptly notify the DA that confiscation procedures will be initiated

• Ensure the availability and/or presence of a veterinarian knowledgeable in 

the species involved

• If it is deemed necessary, obtain the opinion of a second AC VMO or a private 

veterinarian with appropriate expertise with the species involved

• Coordinate confiscation procedures with IES

• Contact Office of the General Counsel (OGC) prior to the issuance of the 

NOIC to have an attorney assigned to the confiscation case for legal 

guidance. The assigned OGC attorney should be provided with the evidence 

supporting the confiscation and review the Notice of Intent to Confiscate 

(NOIC) and the Notice of Confiscation (NOC) before they are issued to the 

licensee.

• Notify Compliance Assurance as early as possible about a potential 

confiscation

• Arrange for appropriate transportation of the confiscated animal(s) including 

trained animal handlers (if needed). Arrange for a Statement of Work, work 

order/ agreement, if required.

• Ensure Legislative and Public Affairs (LPA) has all necessary information, and 

is on board to provide media assistance if needed

• Provide the Office of the Deputy Administrator (ODA) with the most current 

information, to include a summary email or memo listing the number and 

species of animals to be confiscated, the location of the animals, and the 

reason(s) for the confiscation action. A sample of digital photographs/videos 

of the animals and conditions should be included.

• Advise the DA if the suffering animal subject to confiscation is an endangered 

species or a marine mammal, so that coordination with the appropriate 

government agencies can be initiated.

• Draft and obtain approval for the NOC. Forward signed NOC to onsite SACS 

and/or inspector(s)

• Coordinate all proposed legal actions (subpoenas, etc.) with IES, and ensure 

through the assigned OGC attorney that said actions are legal and/or legally 

supportable

• Notify LPA and provide information for the press releases and arrange media 

assistance on site, if indicated (this may be especially important if animals 

will be euthanized)

• Document anticipated expenses in advance and send written estimates of 

costs for products or services to Resource Management Services (RMS)

• When working with animals with contagious diseases, e.g., dogs infected 

with or exposed to canine brucellosis, work with subject matter experts 

(SMEs) to establish a plan to deal with the disease
--- Animal Care Inspection Guide ---

Savedate 3/8/2024 12:55 PM Confiscation Guidance 8-35

8.4.5. Confiscation Timeliness

Reasonable efforts should be made to deliver the NOIC and associated 

inspection report to the licensee, intermediate handler, or carrier. Deadlines for 

corrective actions should not normally exceed 24 hours, typically corrective 

actions should be completed before the end of the day notice was given.

8.4.6. Responsible Person is Unavailable

If the licensee, intermediate handler, or carrier is unavailable, contact AWO 

Management and refer to associated regulation.

8.4.7. IES Responsibilities 

With AWO, determine the specific role of IES in supporting the investigation 

process and their location within the team structure at the confiscation. 

8.4.8. EMSSD Responsibilities

Working with AWO, set up appropriate security FOR THE INCIDENT.

8.4.9. Safety Officer

Assume position responsibilities

Successfully assume role of Safety Officer and initiate position activities at the 

appropriate time according to the following:

Ensure readiness for assignment. 

Obtain and assemble information and materials needed. This will include critical 

items needed for the assignment and items needed for functioning during the 

first 48 hours. 

The basic information and materials needed may include, but is not limited to, 

any of the following: 

• Reference materials appropriate to the confiscation 

• Agency health and safety code handbook. 

• The Animal Care Safety and Health Handbook 

• Safety checklists. 

• Injury and accident forms.

• 100-ft tape

• Clipboard 

• Writing tablet
--- Animal Care Inspection Guide ---

Savedate 3/8/2024 12:55 PM Confiscation Guidance 8-36

• Flashlight and batteries

• Pencils and assortment of magic markers 

• Pocket notebook 

• Camera 

• Compass

• Clinometer or Abney level

• Alarm clock

• Thermometer and wind gauge/belt weather kit 

• Light day pack

• Personal protective equipment (PPE) 

• Chalk

• Binoculars 

• Gather information necessary to assess confiscation assignment and 

determine immediate needs and actions

• Know who the Team Leader/ SACS name, location. Make contact. 

• Know current resource commitments 

• Know current and anticipated situation (hazardous materials, urban 

interface, etc.)

• Know expected duration of assignment. 

Ensure the safety, welfare, and accountability of assigned personnel.

• Recognize potentially hazardous situations

• Inform personnel of hazards

• Ensure that special precautions are taken when extraordinary hazards exist

• Ensure adequate rest is provided to all unit personnel

• Initiate accident investigation team for those accidents that occur within the 

confiscation area

• Ensure confiscation team members are aware of the safety-related aspects 

of their jobs and undertake their job responsibilities in a safe manner based 

on expected duration, size, type of incident, potential values to be protected, 

and jurisdictional involvement

• Develop or implement a safety action plan. Ensure that hazards and risks are 

identified and adequately monitored for the duration of the confiscation. 

Share action plan with the Team Leader and confiscation staff and revise as 

necessary. Ensure any changes in confiscation hazards and risks with relevant 

corrective actions are reflected in the safety action plan, safety messages, 

and/or safety briefings as appropriate.
--- Animal Care Inspection Guide ---

Savedate 3/8/2024 12:55 PM Confiscation Guidance 8-37

• Monitor vehicle/operator time periods. Audit time and equipment records of 

drivers/vehicles to ensure they have not exceeded the standards set by the 

agency. Operators that have been found to exceed these standards will be 

relieved immediately. Document. 

• Monitor food and sanitation conditions. Inspect potable water supplies. 

Inspect potable water sources, hauling, and storage containers. Document 

any deficiencies identified and take corrective actions. Monitor incident 

personal protective equipment needs.

Safety Officer Position Checklist

The following checklist should be considered as the minimum requirements for 

this position. Note that some of the tasks are one-time actions; others are 

ongoing or repetitive for the duration of the confiscation.

1. Obtain briefing from Team Leader/ SACS and/or from initial on-scene Safety 

Officer 

2. Identify hazardous situations associated with the confiscation. Ensure 

adequate levels of protective equipment are available and being used 

3. Staff and organize function, as appropriate: 

o Multiple high-risk operations may require an Assistant Safety Officer at 

each site 

o Request additional staff through the Team Leader/ SACS

4. Identify potentially unsafe acts

5. Identify corrective actions and ensure implementation. Coordinate corrective 

action with Team Leader/SACS

6. Ensure adequate sanitation and safety in food preparation

7. Debrief Assistant Safety Officers prior to Planning Meetings

8. Prepare confiscation action plan safety and risk analysis

9. Participate in planning meetings: 

o Listen to options being considered. If potentially unsafe, assist in 

identifying options, protective actions, or alternate actions

8.4.10. Logistics Officer (if utilized)

Core functions:

• Acquisition of personnel

• Transportation

• Services for responders: lodging, food, medical care

• Communications
--- Animal Care Inspection Guide ---

Savedate 3/8/2024 12:55 PM Confiscation Guidance 8-38

• Acquisition of equipment and supplies

Logistics Checklist

Not all listed tasks or concerns will apply to every incident

* Asterisk indicates all or some of the core function could be supported offsite

 *Acquisition of Personnel

• Respond to requests for personnel 

o Confirm supervisor approval for APHIS personnel

o Identify non-APHIS personnel needed and mobilize them via appropriate 

processes in coordination with AWO

o Coordinate law enforcement mobilization with EMSSD Security 

 *Transportation 

• Monitor and facilitate travel to incident scene (air, GOV, POV, rental cars, 

etc.)

o Engage AWO for support and support non-Federal travel as appropriate

• Monitor and facilitate travel from staging/hotel to incident scene and back

• Animal transportation: Trucks, trailers, and other conveyances

o Evaluate for capacity, safety, and environment (temperature/ventilation)

o Consult with Finance, Team Leader, AD, AWO Director on costs

• Fuel, repairs, and other transportation issues

• Re-evaluate responder transportation resources and assignments

 *Responder Services (Facilities, Medical, and Food Units)

• Lodging and meeting rooms

o Ensure that appropriate lodging is identified and that all responders have 

made appropriate reservations

o Ensure that a location is identified for critical actions, including onsite 

planning meetings, staging or personnel and equipment, and the 

operational briefing

• Food and beverage: Ensure that appropriate access to food and beverage is 

available for planning and staging areas as well as confiscation scene

• Provide Responder Medical Plan information

o Offsite- Hospitals/Minor emergency/ambulance/Air Ambulance Services

- Provide directions to above as appropriate

- Provide a description of scene for emergency communication 

(address, GPS, clear directions to convey to emergency services 

personnel)
--- Animal Care Inspection Guide ---

Savedate 3/8/2024 12:55 PM Confiscation Guidance 8-39

o Determine if onsite- EMS (Local) is necessary 

- Consult with Team Leader, Safety Officer, EMSSD Security, AWO 

Director

- Arrange if necessary

o Update Responder Medical Plan as needed throughout the confiscation 

detail

• Brief personnel on Responder Medical Plan

 *Communications 

• Assess communication needs:

o Cell phone coverage, Internet availability

o Radios (how many, is a repeater needed, which responders have radios, 

additional base stations and handheld radios needed)

• Arrange shipping/transport for all communications equipment and supplies

• Create Communications Plan, as appropriate

o Create communications directory of onsite and support personnel

o Create radio frequency plan (APHIS and non-APHIS personnel)

o Transmit just-in-time/refresher radio training documents for team

• Implement and support Communications Plan during on-scene operations

o Issue radios and other equipment and supplies as appropriate

o Brief response personnel on Communications Plan

o Test 911 via cellular telephone if appropriate for the location (such as 

locations near the border of multiple jurisdictions)

o Work with APHIS CEC to resolve IT/communications issues as appropriate

 *Acquisition of equipment and supplies

• Anticipate and obtain materials requested by Team Leader, other APHIS 

personnel, and partner agencies as appropriate including:

o Animal assessment & care (veterinary, care/restraint/capture, PPE, 

animal food/water)

o Animal relocation equipment and supplies (crates, cages, vehicles, 

drivers, fuel)

o Ensure handwashing and alcohol- based hand sanitizers are available

o Drinking water purchases must be made by individual using their per 

diem or in accordance with the MRPBS water purchase policy

• Distribute equipment and supplies to response personnel, including personal 

protective equipment and document in Unit Log as appropriate

• Recover assigned equipment and excess supplies from demobilizing 
--- Animal Care Inspection Guide ---

Savedate 3/8/2024 12:55 PM Confiscation Guidance 8-40 

personnel

• Organize operations to ensure efficiency and personnel safety

o Ensure that all participating organizations, such as APHIS IES, USDA OIG, 

State agencies, law enforcement, local animal control, or NonGovernmental Organizations are included in the organization of the 

confiscation.

 Establish timelines

o Most APHIS AC confiscation actions will be accomplished onsite in one 

time period

o Some actions may require more than one onsite time period or an off-site 

period of time to wrap up

o An exceptional situation might require management of confiscated 

animals onsite with prolonged efforts to relocate animals. Alternatively, 

a support operation for a facility engaged in voluntary relocation of 

animals as an alternate to confiscation might necessitate multiple 

operational periods. In protracted incidents, operational time periods 

might extend to weekly or biweekly.

 Assess safety

o Ensure security of facility perimeters and adjust perimeter as necessary

o Evaluate and enforce the use of appropriate PPE and safety equipment

o Implement and enforce appropriate safety precautions (in collaboration 

with Safety Officer)

 Determine need and request additional resources 

o Resource needs are assessed 

o Resource requests communicated to Team Leader/ SACS

o Team Leader and/or AD/AWO Director may need to authorize certain 

additional resources

 Attend Planning Meetings
--- Animal Care Inspection Guide ---

Savedate 3/8/2024 12:55 PM Confiscation Guidance 8-41

8.5. Sample Documents 

Notice of Intent to Confiscate

Notice of Confiscation

Statement of Work
--- Animal Care Inspection Guide ---

Savedate 3/8/2024 12:55 PM Confiscation Guidance 8-42
--- Animal Care Inspection Guide ---

Savedate 3/8/2024 12:55 PM Confiscation Guidance 8-43

Federal Relay Service (Voice/TTY/ASCII/Spanish)

 1-800-877-8339

United States

Department of

Agriculture

Marketing and

Regulatory

Programs

Animal and 

Plant Health 

Inspection

Service

Animal Care

2150 Centre Ave,

Building B, 3W11

Fort Collins, CO 

80526 

(970) 494-7478

Fax: 472-9558

Animal and Plant Health Inspection Service

Safeguarding American Agriculture

An Equal Opportunity Employer

 

TO: [FACILITY REPRESENTIVE NAME]

[FACILITY ADDRESS]

USDA License #

FROM: [NAME]

Administrator

 Animal and Plant Health Inspection Service

 U.S. Department of Agriculture

DATE: [DATE NOC WILL BE DELIVERED]

SUBJECT: Notice of Confiscation of Animals

PLEASE TAKE NOTICE that the following animals owned by [LICENSEE/REGISTRANT NAME], which are 

currently maintained by you at [FACILITY ADDRESS], are hereby confiscated by the U.S. Department of 

Agriculture, Animal and Plant Health Inspection Service, pursuant to section 16 of the Animal Welfare Act (7 

U.S.C. _ 2146) and Title 9, Code of Federal Regulations, section 2.129 (9 C.F.R. _ 2.129), for the failure to provide 

the adequate and necessary care to the animals.

Animals: [LIST ALL ANIMALS WE WILL CONFISCATE]

_________________________

[NAME]

Administrator 

Animal and Plant Health Inspection Service

U.S. Department of Agriculture

Received by: _________________________ Date_____________

Title: ________________________________
--- Animal Care Inspection Guide ---

Savedate 3/8/2024 12:55 PM Confiscation Guidance 8-44

Sample Statement of Work

USDA

Animal Care

Licensee/ Registrant Name

Statement of Work

Describe number of and species of animals involved

Working Date (dates of confiscations may change)
--- Animal Care Inspection Guide ---

Savedate 3/8/2024 12:55 PM Confiscation Guidance 8-45

Statement of Work (SOW)

for the

(Description of Confiscation)

1.0 General

1.1 Background 

A key part of the purpose of USDA APHIS Animal Care is to ensure the humane 

treatment of animals covered by the Animal Welfare Act. Animal Care 

inspectors and management are working together to ensure the animals located 

at (licensee facility) in (City, State) that are most at risk of (description of issue) 

be removed as soon as possible to prevent the animals from further suffering. 

The animals most at risk have been determined to be (description of the animals 

to be transported). 

1.2 Objective

The objective is to safely remove XX (name species) that have been identified as 

“at risk” animals and transport the animals to (name the facility and the means 

of transportation) 

1.3 Scope of Work

(SAMPLE DESCRIPTION)

The contractor will travel from their facility in City, State to the licensee’s facility 

in City, State, approximately XXX miles each way. The contractor will be 

responsible for:

Providing the appropriate transport vehicles and transport cages necessary to 

move XXX animals. Add brief description of the animals to be transported.

Assisting with loading the animals into transport cages which may include 

immobilizing (tranquilizing) some of the (name species) to ensure safety of both 

the personnel and the (species) 

Furnishing a veterinarian with experience working with, and immobilizing (name 

species) 

Providing all drugs, supplies and equipment necessary to immobilize and safely 

move (name species) 

1.4 Period of Performance

SAMPLE DESCRIPTION

The period of performance of this contract is approximately a (estimate how 

long the operation should take from when the contractor leaves until they 

return to their facility) xxx hour period and is dependent on the dates that best 

work for the security of the personnel, and for removing the (species) in a timely 

manner once the intent to confiscate is issued. The working date of this 

operation is INSERT DATE HERE but may be subject to change. It is understood 

the contractor will need to travel to City, State the night before the operation. 
--- Animal Care Inspection Guide ---

Savedate 3/8/2024 12:55 PM Confiscation Guidance 8-46

1.5 Place of Performance

Facility located in City, State 

2.0 Specific Requirements/Tasks

2.1 Task One 

Load (name species) into Transport Enclosures

Safely load (species), listed below, into (species specific) transport enclosures 

furnished by the contractor. This process involves the use of a series of 

veterinary supplies (get list of necessary supplies from contractor) (EXAMPLE) 

including drugs for immobilization, emergency drugs, fluids and drip sets, and 

blood testing supplies to screen for nutritional disease and other diseases. 

(EXAMPLE) A forklift or other lifting device may be necessary and should be on 

hand to move the larger cages into position to load the (species), and to load 

(species) that are in the transport cages into the transport vehicles. 

It may be necessary to define how the animals are housed and the general plan 

to load the animals into transport enclosures

The groupings of the XX identified (species) are listed as how the animals are 

presently housed. The adult (species), four 10-month old (species), and two 8-

month-old (species) may be able to be lured into transport containers without 

the need for immobilization. However, the contractor should be prepared to 

immobilize these (species) to safely load them in to transport enclosures. The 

cubs and younger juveniles may likely be captured safely without the need to 

immobilize them. 

SAMPLE OF LIST OF ANIMALS INVOLVED

Jackie female (Born 3/27/20) dam is Sally

Marsha female (Born 3/27/20) dam is Sally

Jack male (Born 4/2/2020) dam is Sasha

Sarah female (Born 4/2/2020) dam is Sasha

Lila female (born 5/5/20) dam is Esi 

Peter male (born 5/8/20) dam is Tina

Shasta female (born 9/5/2020) dam is Gaylen

Chandra female (born 9/5/2020) dam is Gaylen

Charlie male (born 11/28 2020) dam is Patsy

Myrnah female (born 11/28/ 2020) dam is Patsy 

Patsy (mother born 9/26/18) (mother of Charlie and Myrnah)
--- Animal Care Inspection Guide ---

Savedate 3/8/2024 12:55 PM Confiscation Guidance 8-47

2.2 Task Two Transport (species) to facility in (City, State) 

Once loaded into transport enclosures, the (species) will be transported via 

truck, truck/trailer, or car to the (Name of Facility) in (City, State), a distance of 

approximately XXX miles. This operation will require X vehicles. 

2.3 Task Three: Ensure (species) are fit for travel and have appropriate 

vaccinations

These (species) have had questionable veterinary care and should be screened 

for diseases and vaccinated if deemed necessary prior to being shipped to (City, 

State).

3.0 Delivery or Deliverables 

The working date for this operation is (List Date). The crew responsible for the 

loading and removal of the (species) is expected to be stationed close enough to 

the Licensee facility the night prior to the operation so that they can be ready to 

perform this operation first thing in the morning of the operation following a 

security briefing.

4.0 Required Travel and Other Direct Costs (ODCs)

Travel will be required for a team of X personnel, one of which is a veterinarian 

with experience working with, and immobilizing (species), and all personnel 

trained and experienced working with and around (age and species). This team 

will require X rooms at a per diem rate of $Per Diem Rate per room for one 

night, and a per diem rate of $XX.00 per person for X people, for a period not 

more than X days. The working date of this operation is (LIST DATE), with 

expected travel to (Licensee City, Date) the day before the operation. 

X vehicles will be necessary for this operation. The distance between the 

Contractor’s facility in (name State) and the Licensee’s facility (City State) is 

approximately XXX miles. Mileage at $0.56 per mile for X vehicles for XXX miles 

for each vehicle would be an estimated $TOTAL COST. 

5.0 Government Furnished Property/Equipment/Information

SAMPLE DESCRIPTION: 

The government will be furnishing a security team as well as 2-3 Veterinary 

Medical Officers and a Zoological Field Specialist who is a veterinarian and is 

Board Certified with the American College of Zoological Medicine. The 

government veterinarians will oversee the operation and ensure the operation 

runs smoothly and are there to assist if there are any veterinary emergencies. 

The security team will provide security to all personnel involved in this 

operation.
--- Animal Care Inspection Guide ---

Savedate 3/8/2024 12:55 PM Confiscation Guidance 1 

Appendices

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

hyperlinks.

Contents

Appendix A. Forms and Worksheets A-1

Appendix B. General Information B-1

Appendix C. NCI/Direct/Critical Noncompliance Examples C-1

Appendix D. Equipment and Supplies D-1

Appendix E. Body Condition and Size Charts E-1

Appendix F. Acronyms F-1
Savedate 3/8/2024 12:55 PM Forms and Worksheets A-1 

Appendix A. 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 A-12

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

Unsatisfactory Optimal Hours Response Letter A-19

Bird Breeder/Exhibitor Pre-License List A-20
--- Animal Care Inspection Guide ---

Savedate 3/8/2024 12:55 PM 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 

APHIS 7093 – Contingency Planning Program 
--- Animal Care Inspection Guide ---

Savedate 3/8/2024 12:55 PM Forms and Worksheets A-3 

Amended Inspection Report Letter
--- Animal Care Inspection Guide ---

Savedate 3/8/2024 12:55 PM Forms and Worksheets A-4

Attempted Inspection Checklist
--- Animal Care Inspection Guide ---

Savedate 3/8/2024 12:55 PM Forms and Worksheets A-5

Attempted Inspection Leave-Behind Flyer
--- Animal Care Inspection Guide ---

Savedate 3/8/2024 12:55 PM Forms and Worksheets A-6

Attempted Inspection Letter and Enclosure
--- Animal Care Inspection Guide ---

Savedate 3/8/2024 12:55 PM Forms and Worksheets A-7
--- Animal Care Inspection Guide ---

Savedate 3/8/2024 12:55 PM Forms and Worksheets A-8

Attempted Inspection – Script Following an Attempted Inspection 
--- Animal Care Inspection Guide ---

Savedate 3/8/2024 12:55 PM Forms and Worksheets A-9
--- Animal Care Inspection Guide ---

Savedate 3/8/2024 12:55 PM Forms and Worksheets A-10
--- Animal Care Inspection Guide ---

Savedate 3/8/2024 12:55 PM Forms and Worksheets A-11
--- Animal Care Inspection Guide ---

Savedate 3/8/2024 12:55 PM Forms and Worksheets A-12

Complaint Worksheet

(For internal use only)
--- Animal Care Inspection Guide ---

Savedate 3/8/2024 12:55 PM Forms and Worksheets A-13

Environmental Enrichment Plan Inspection Checklist
--- Animal Care Inspection Guide ---

Savedate 3/8/2024 12:55 PM Forms and Worksheets A-14
--- Animal Care Inspection Guide ---

Savedate 3/8/2024 12:55 PM Forms and Worksheets A-15

Facility Contact Worksheet
--- Animal Care Inspection Guide ---

Savedate 3/8/2024 12:55 PM Forms and Worksheets A-16

Inspection Report Review Checklist
--- Animal Care Inspection Guide ---

Savedate 3/8/2024 12:55 PM Forms and Worksheets A-17
--- Animal Care Inspection Guide ---

Savedate 3/8/2024 12:55 PM Forms and Worksheets A-18 

Search for Unlicensed Activity Worksheet

(For APHIS Internal Use Only)
--- Animal Care Inspection Guide ---

Savedate 3/8/2024 12:55 PM Forms and Worksheets A-19

Unsatisfactory Optimal Hours Response Letter
--- Animal Care Inspection Guide ---

Savedate 3/8/2024 12:55 PM Forms and Worksheets A-20

Bird Breeder/Exhibitor Pre-License List
--- Animal Care Inspection Guide ---

Savedate 3/8/2024 12:55 PM Forms and Worksheets A-21
--- Animal Care Inspection Guide ---

Savedate 3/8/2024 12:55 PM General Information B-1 

Appendix B. 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 3/8/2024 12:55 PM 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 3/8/2024 12:55 PM General Information B-3

Options for Identification of Dogs and Cats
--- Animal Care Inspection Guide ---

Savedate 3/8/2024 12:55 PM 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 3/8/2024 12:55 PM 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 VIRGINIA

65 MISSISSIPPI 55 NORTH CAROLINA

43 MISSOURI 56 SOUTH CAROLINA

81 MONTANA 57 GEORGIA

47 NEBRASKA 58 FLORIDA

88 NEVADA 61 KENTUCKY

12 NEW HAMPSHIRE 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 3/8/2024 12:55 PM NCI/Direct/Critical Noncompliance Examples C-1 

Appendix C. NCI/Direct/Critical Noncompliance 

Examples

Contents

Examples for Dogs and Cats C-3

Examples for Other Animals C-14
--- Animal Care Inspection Guide ---

Savedate 3/8/2024 12:55 PM 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 should be cited on the 

Inspection Report. 

Any issue that does not rise to the level of an NCI is in compliance.
--- Animal Care Inspection Guide ---

Savedate 3/8/2024 12:55 PM NCI/Direct/Critical Noncompliance Examples C-3 

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

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.
--- Animal Care Inspection Guide ---

Savedate 3/8/2024 12:55 PM NCI/Direct/Critical Noncompliance Examples C-4 

Condition NCI Direct Critical

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.

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.
--- Animal Care Inspection Guide ---

Savedate 3/8/2024 12:55 PM NCI/Direct/Critical Noncompliance Examples C-5 

Condition NCI Direct Critical

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.

Teeth Mild to moderate tartar 

and associated gingivitis 

(red, swollen gums, minor 

bleeding). Recessed gums 

without 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).
--- Animal Care Inspection Guide ---

Savedate 3/8/2024 12:55 PM NCI/Direct/Critical Noncompliance Examples C-6 

Condition NCI Direct Critical

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.

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.
--- Animal Care Inspection Guide ---

Savedate 3/8/2024 12:55 PM NCI/Direct/Critical Noncompliance Examples C-7 

Condition NCI Direct Critical

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. 

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.
--- Animal Care Inspection Guide ---

Savedate 3/8/2024 12:55 PM NCI/Direct/Critical Noncompliance Examples C-8 

Regulation NCI Direct Critical

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).

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. 
--- Animal Care Inspection Guide ---

Savedate 3/8/2024 12:55 PM NCI/Direct/Critical Noncompliance Examples C-9 

Regulation NCI Direct Critical

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).

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.
--- Animal Care Inspection Guide ---

Savedate 3/8/2024 12:55 PM NCI/Direct/Critical Noncompliance Examples C-10 

Regulation NCI Direct Critical

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.

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. 
--- Animal Care Inspection Guide ---

Savedate 3/8/2024 12:55 PM NCI/Direct/Critical Noncompliance Examples C-11 

Regulation NCI Direct Critical

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. 

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.
--- Animal Care Inspection Guide ---

Savedate 3/8/2024 12:55 PM NCI/Direct/Critical Noncompliance Examples C-12 

Regulation NCI Direct Critical

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. 

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.
--- Animal Care Inspection Guide ---

Savedate 3/8/2024 12:55 PM NCI/Direct/Critical Noncompliance Examples C-13 

Regulation NCI Direct Critical

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.

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. 
--- Animal Care Inspection Guide ---

Savedate 3/8/2024 12:55 PM NCI/Direct/Critical Noncompliance Examples C-14 

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. 

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. 

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. 

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

(a) Structural 

Strength

Facilities not maintained; 

animals escape and are 

returned to enclosure 

unharmed

Facilities not maintained; during 

the inspection animals escaped 

and were severely injured or died

Facilities not maintained; prior to the 

inspection animals escaped and were 

not recaptured or were severely 

injured or died
--- Animal Care Inspection Guide ---

Savedate 3/8/2024 12:55 PM NCI/Direct/Critical Noncompliance Examples C-15 

Regulation NCI Direct Critical

(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.

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.

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.
--- Animal Care Inspection Guide ---

Savedate 3/8/2024 12:55 PM NCI/Direct/Critical Noncompliance Examples C-16 

Regulation NCI Direct Critical

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.

(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 3/8/2024 12:55 PM 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 3/8/2024 12:55 PM 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 hardsurfaced 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 3/8/2024 12:55 PM 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 3/8/2024 12:55 PM Equipment and Supplies D-1 

Appendix D. 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 3/8/2024 12:55 PM 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 3/8/2024 12:55 PM 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 3/8/2024 12:55 PM Body Condition and Size Charts E-1 

Appendix E. Body Condition and Size Charts

Contents

Birds E-2

Cat E-3

Cougar E-4

Dog E-5

Elephant E-6

Leopard E-7

Lion E-8

Tiger E-9

Tiger cub size information E-10

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 3/8/2024 12:55 PM Animal Welfare Inspection Guide E-2 

Birds

For bird body condition information, go to:

https://nagonline.net/wp-content/uploads/2017/03/pet-size-o-meter-birds.pdf

from which the below illustration was excerpted and adapted. 
--- Animal Care Inspection Guide ---

Savedate 3/8/2024 12:55 PM Animal Welfare Inspection Guide E-3

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 3/8/2024 12:55 PM Animal Welfare Inspection Guide E-4

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 3/8/2024 12:55 PM Animal Welfare Inspection Guide E-5

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 3/8/2024 12:55 PM Animal Welfare Inspection Guide E-6

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 3/8/2024 12:55 PM Animal Welfare Inspection Guide E-7

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 3/8/2024 12:55 PM Animal Welfare Inspection Guide E-8

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 3/8/2024 12:55 PM Animal Welfare Inspection Guide E-9

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 3/8/2024 12:55 PM Animal Welfare Inspection Guide E-10

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 3/8/2024 12:55 PM Animal Welfare Inspection Guide E-11

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 3/8/2024 12:55 PM Animal Welfare Inspection Guide E-12

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 3/8/2024 12:55 PM Animal Welfare Inspection Guide E-13

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 3/8/2024 12:55 PM Animal Welfare Inspection Guide E-14

Age Weight (pounds) Photograph

20 weeks 55 – 68

Source: Bronx Zoo, Bronx NY http://bronxzoo.com
--- Animal Care Inspection Guide ---

Savedate 3/8/2024 12:55 PM Animal Welfare Inspection Guide F-1

Appendix F. 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

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