The Animal Welfare Act (AWA) and regulations set standards 

of care and treatment for certain animals used in research, 

experimentation, teaching, and/or testing. While the AWA 

regulations cover many types of activities, they include 

some exceptions for field research involving wild animals in 

their natural habitat. 

The following is quick guidance to assist Institutional 

Animal Care and Use Committees (IACUCs) at research 

facilities in determining whether an activity meets the 

AWA regulatory definition of “field study” and is therefore 

exempt from oversight or is otherwise covered under the 

AWA regulations. The AWA itself establishes the legal 

requirements and standards facilities must follow. For 

details, refer to the AWA (United States Code, Title 7, 

Chapter 54, Sections 2131–2159) and the Animal Welfare 

Regulations (Code of Federal Regulations, Title 9, Chapter 

1, Subchapter A, Parts 1–4).

AWA Regulatory Definitions

Field study: A study conducted on free-living wild animals in 

their natural habitat. However, this term excludes any study 

that involves an invasive procedure, harms, or materially 

alters the behavior of an animal under study. 

Wild animal: Any animal that is now or historically has been 

found in the wild, or in a wild state, within the boundaries of the 

United States, its Territories, or possessions. This term includes 

but is not limited to animals such as deer, skunk, opossum, 

raccoon, mink, armadillo, coyote, squirrel, fox, and wolf. 

Major operative procedure: Any surgical intervention that 

penetrates and exposes a body cavity or any procedure 

which produces permanent impairment of physical or 

physiological functions. 

Euthanasia: 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. 

Role of the IACUC

All research facilities must have an IACUC. Per the AWA, the 

IACUC is responsible for overseeing and assessing all aspects 

of the facility’s animal program, including inspecting animal 

facilities and study areas, investigating complaints of inhumane 

animal care, and approving or suspending animal research 

activities. The IACUC is therefore responsible for evaluating 

whether an activity with wild animals is regulated under the 

AWA. Note: Animal areas containing free-living animals in their 

natural habitat need not be included in inspections. 

The IACUC is to be composed of members with sufficient 

experience and expertise to evaluate a research facility’s 

animal program, facilities, and procedures using animals. 

Ad hoc consultants may be invited to assist with the 

evaluations. For example, IACUC members may have 

sufficient expertise in-house to evaluate biomedical research 

activities but may need to consult outside experts to advise on 

field research with wild animals. 

If the IACUC determines a research activity is regulated under 

the AWA, that activity falls under IACUC oversight and must be 

reviewed semiannually. If the IACUC determines an activity is 

not AWA-regulated, that activity is not subject to IACUC review. 

Research With Free-Living Wild Animals in Their 

Natural Habitat and the Animal Welfare Act 

Animal Care Tech Note
USDA is an equal opportunity provider, employer, and lender. www.aphis.usda.gov/animal-welfare APHIS 41-35-083 ▪ Revised January 2022

Quick Guidance

Examples AWA 

Oversight Reason

Procedures where pain/distress 

is slight or momentary and does 

not impact well-being, such as:

• Observational studies 

where no animals are 

captured or handled 

• Observational studies where 

human presence does not 

impact animal behavior

Exempt Meets the AWA 

definition of field study

Activities involving 

invertebrates, reptiles, 

amphibians, and fish

Activities where the species is 

being used for food, fur, or fiber

Exempt Species not covered 

under the AWA

Animal, pest, and population 

management programs 

(e.g., culling, relocation, and 

nonsurgical sterilization) for 

the purposes of limiting wildlife 

damage and human interaction

Exempt Activity not covered 

under the AWA (not 

performed for the 

purposes of research, 

teaching, testing, or 

experimentation)

Studies that involve: 

• major operative procedures

• intra-cardiac blood collections 

• arterial/venous cut downs 

for catheter placement 

• surgical implantation of 

devices 

Regulated Involves an invasive 

procedure; does 

not meet the AWA 

definition of field study

Studies in which an animal 

experiences:

• pain/distress above minimal 

and slight

• trauma, overheating, 

excessive cooling, behavioral 

stress, physical harm, or 

unnecessary discomfort as a 

result of handling 

• death as a result of the 

work, in a manner that does 

not meet the regulatory 

definition of “euthanasia” 

• impaired function such as 

amputation of a tail/digit 

used for digging or climbing 

Regulated Harms an animal 

under study; does 

not meet the AWA 

definition of field study

Procedures or activities that: 

• use hormones or 

pheromones to change 

mating or migration patterns 

for research purposes 

• cause repeated nest/den 

disturbance during breeding 

and rearing of young

• relocate migratory animals 

beyond natural migration 

routes for research

Regulated Materially alters the 

behavior of an animal 

under study; does 

not meet the AWA 

definition of field study

Registration and Annual Reporting

Any facility that conducts AWA-regulated research activities 

must register with the U.S. Department of Agriculture (USDA) 

as a research facility and meet the law’s standards for 

humane animal care. Federal research facilities are not 

required to register with USDA but must adhere to the AWA 

standards. Federal and non-Federal facilities are required to 

submit an annual report on animal usage to USDA. Animals 

used in work that meets the regulatory definition of a field 

study are not to be included in the annual report.

Research facilities that conduct only field studies or other 

exempt activities do not need to register with USDA. Such 

facilities are not regulated under the AWA.

For More Information

USDA APHIS Animal Care 

4700 River Road, Unit 84 

Riverdale, MD 20737 

animalcare@usda.gov