USDA-APHIS-Animal Care 

Animal Welfare Act

Summary Changes to Policy #3 – Veterinary Care 

Policy #3: Veterinary Care: 

Expired Medical Materials

Pharmaceutical-Grade Compounds in Research

Surgery 

Pre- and Post- Procedural Care 

Program of Veterinary Care 

Declawing and Defanging Practices in Wild or Exotic 

Carnivores or Nonhuman Primates 

Health Records 

Euthanasia 

 

 

Change to: Pharmaceutical-Grade Substances in 

Research

 

Issue Date: March 25, 2011 Change to: XXXXX, 2013

References:

AWA Section 2143 

9 CFR, Part 2, Sections 2.31, 2.32, 2.33, 2.40

9 CFR, Part 3, Section 3.110 

No Change

History:

Replaces memoranda dated May 31, 1990; November 29, 

1991; April 6, 1992; and September 25, 1992. Replaces 

policies dated April 14, 1997; January 14, 2000; August 

18, 2006; and July 17, 2007.

Add: September XXX, 2013

Justification:

Provides requested guidance. The Animal Welfare Act 

(AWA) requires that all regulated animals be provided 

adequate veterinary care. 

No Change

Policy: Expired Medical Materials

The use of expired medical materials such as drugs, 

fluids, or sutures on regulated animals is not considered 

to be acceptable veterinary practice and is not consistent 

with adequate veterinary care as required by the 

regulations promulgated under the Animal Welfare Act. 

The facility should either dispose of all such materials or 

segregate them in an appropriately labeled, physically 

separate location from non-expired medical materials. 

Change to:

The use of expired medical materials (e.g., drugs, 

fluids, sutures, anesthetics, or analgesics) during 

any surgical procedure is not considered 

acceptable veterinary practice and therefore not 

consistent with adequate veterinary care as 

required by the regulations promulgated under 

the Animal Welfare Act. However, expired 

medical materials except analgesics, anesthetics, 

and euthanasia solutions may be used in acute 

terminal procedures where an animal is 

anesthetized during the study and euthanized 

without recovery if such use does not adversely 

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USDA-APHIS-Animal Care 

Animal Welfare Act

Summary Changes to Policy #3 – Veterinary Care 

The Animal and Plant Health Inspection Service (APHIS), 

Animal Care (AC) has no jurisdiction over facilities using 

expired medical materials for non-regulated animals or 

non-regulated activities. 

For acute terminal procedures, where an animal is put 

under anesthesia, the research is carried out (surgery or 

testing of a compound) and the animal is euthanized 

without ever waking up, medical materials may be used 

beyond their "to be used by" date if such materials use 

does not adversely affect the animal’s wellbeing or 

compromise the validity of the scientific study. 

Anesthesia, analgesia, emergency drugs and euthanasia 

drugs that are within their expiration dates are required 

for all such procedures. Facilities allowing the use of 

expired medical materials in acute terminal procedures 

should have a policy covering the use of such materials 

and/or require investigators to describe in their animal 

activity proposals the intended use of expired materials.

The attending veterinarian and the Institutional Animal 

Care and Use Committee (IACUC) are responsible for 

ensuring that proposed animal activities avoid or 

minimize discomfort, distress, and pain to the animal. 

APHIS has determined that these responsibilities cannot 

be met unless the veterinarian and the IACUC maintain 

control over the use of expired medical materials. 

affect the animal’s well-being or compromise the 

validity of the scientific study. 

Facilities permitting the use of expired medical 

materials in acute terminal procedures should 

have a policy on the use of such materials and/or 

require investigators to describe the intended 

use in the animal study proposal. 

The Animal and Plant Health Inspection Service/ 

Animal Care (APHIS/AC) has determined that the 

attending veterinarian along with the IACUC 

should control the use of expired medical 

materials in order to comply with the regulatory 

requirement to ensure pain and distress is 

minimized during proposed activities. 

Expired materials should be segregated from 

non-expired medical materials in an 

appropriately labeled, physically separate 

location or discarded. APHIS however has no 

jurisdiction over the possession and use of 

expired medical materials for non-regulated 

animals and activities. 

Pharmaceutical-Grade Compounds in Research

 

Investigators are expected to use pharmaceutical-grade 

medications whenever they are available, even in acute 

procedures. Non-pharmaceutical- grade chemical 

compounds should only be used in regulated animals 

after specific review and approval by the IACUC for 

reasons such as scientific necessity or non-availability of 

an acceptable veterinary or human pharmaceutical-grade 

product. Cost savings is not a justification for using nonpharmaceutical-grade compounds in regulated animals. 

Change to: Pharmaceutical-Grade Substances in 

Research 

Investigators are expected to use 

pharmaceutical-grade substances whenever they 

are available, even in acute procedures. This 

includes but is not limited to: compounds, 

medications, drugs, vehicles, and diluents. Nonpharmaceutical-grade substances should only be 

used in regulated animals after specific review 

and approval by the IACUC. The IACUC should 

develop a consistent evaluation process which 

includes but not limited to the scientific 

justification and the availability of an acceptable 

veterinary or human pharmaceutical-grade 

product. Cost savings alone is not sufficient 

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Animal Welfare Act

Summary Changes to Policy #3 – Veterinary Care 

justification for using a non-pharmaceuticalgrade substance in regulated animals. APHIS 

recognizes that most test articles and novel 

compounds are by definition not available in 

pharmaceutical grade.

Consultation with the attending veterinarian and 

consideration of alternatives are required when 

procedures that use non-pharmaceutical grade

substances may potentially cause more than 

slight or momentary pain or distress. 

Surgery Surgery

ADD: 

Professional Standards and Established 

Procedures: Current professional standards 

preclude eating, drinking, or smoking in surgery 

areas. Locations used for food handling purposes 

do not qualify as acceptable areas for performing 

surgeries. 

Survival Surgeries: AWA regulations require that survival 

surgeries be performed using aseptic techniques and that 

major operative procedures on nonrodents be performed 

only in dedicated surgical facilities. For the purposes of 

this policy, designated surgical facilities are those that 

are set up to be cleaned and maintained in an aseptic 

condition, and are not used for other purposes when 

they are not being used for surgery. They must be 

maintained in good repair to meet aseptic requirements. 

No Change

APHIS has determined that motel meeting rooms and 

auditoriums do not qualify as dedicated surgical facilities. 

Change to: APHIS has determined that hotel 

meeting rooms and auditoriums do not qualify as 

dedicated surgical facilities. 

Nonsurvival Surgeries: Nonsurvival surgeries do not 

require aseptic techniques or dedicated facilities but 

should be performed in a clean area, free of clutter, and 

using acceptable veterinary sanitation practices 

equivalent to those used in a standard 

examination/treatment room. Personnel present in the 

area should observe reasonable cleanliness practices for 

both themselves and the animals.

No Change

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Animal Welfare Act

Summary Changes to Policy #3 – Veterinary Care 

Add: The performance of nonsurvival surgeries 

in hotel meeting rooms and auditoriums as 

practiced in instances such as teaching situations

and demonstration can only occur provided the 

requirements for nonsurvival surgery and 

minimizing pain and distress are met. 

Current professional standards preclude eating, drinking, 

or smoking in surgery areas, and locations used for food 

handling purposes do not qualify as acceptable areas for 

performing surgeries. 

The change: paragraph moved to the beginning 

of the surgery section.

Pre- and Post-Procedural Care

All animal activity proposals involving surgery must 

provide specific details of pre- through post-procedural 

care and relief of pain and distress. The principal 

investigator must involve the attending veterinarian or 

his/her designee in planning the type of care that may be 

provided. The appropriate use of drugs to relieve pain 

and/or distress should be specified in the animal activity 

proposal to avoid possible delays due to investigator 

concerns that a treatment regimen may interfere with 

the study. Furthermore, the specified drugs for relief of 

pain and/or distress must be readily available for use as 

described in the proposal. However, the attending 

veterinarian retains the authority to alter post-operative 

care if unexpected pain and/or distress occur in an 

animal. The IACUC must approve a significant change to 

the protocol if the attending veterinarian requests to 

alter post-operative care for the remaining animals. The 

withholding of pain and/or distress relieving care must 

be scientifically justified in writing and approved by the 

IACUC. 

While an animal is under post-surgical care, the 

ownership of the animal is not to change. If the animal is 

taken to an off-site location, such as a farm, for postoperative care, that location should be identified as a site 

of the research facility or a site of another registered 

research facility in order for AC to conduct an inspection.

To comply with adequate veterinary care requirements 

and in accordance with currently accepted standards of 

practice, an animal is not to be taken to an off-site 

location before it fully recovers from anesthesia unless 

justified in the animal activity proposal. Appropriate 

No Change

 

Change to: In the event the animal is taken to an 

off-site location, such as a farm, for postoperative care, that location should be identified 

as a site of the research facility or a site of 

another registered research facility in order for 

AC to conduct an inspection.

No Change

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Animal Welfare Act

Summary Changes to Policy #3 – Veterinary Care 

post-operative records should be maintained in 

accordance with professionally accepted veterinary 

procedures regardless of the location of the animal. 

Program of Veterinary Care

Facilities which do not have a full-time attending 

veterinarian must have a written Program of Veterinary 

Care (PVC). This Program must consist of a properly 

completed APHIS Form 7002 or an equivalent format. 

The attending veterinarian must visit the facility on a 

regular basis, i.e., often enough to provide adequate 

oversight of the facility’s care and use of animals. APHIS 

recommends this visit occur at least annually. Records of 

visits by the attending veterinarian should be kept to 

include dates of the visits and comments or 

recommendations of the attending veterinarian or other 

veterinarians. 

The PVC should be reviewed and updated whenever 

necessary (e.g., as a new species of animal or a new 

attending veterinarian is obtained, or the preventive 

medical program changes). APHIS recommends that the 

PVC be initialed and dated by both the attending 

veterinarian and the facility representative whenever it is 

changed or reviewed without change. The preventive 

medical program described in the PVC is expected to be 

in accordance with professionally accepted veterinary 

practice (e.g., appropriate vaccinations, diagnostic 

testing). It should include zoonotic disease prevention 

measures 

No Change

Declawing and Defanging Practices in Wild or Exotic 

Carnivores or Nonhuman Primates

Declawing of wild and exotic carnivores and the removal 

or reduction of canine teeth in nonhuman primates and 

wild and exotic carnivores have been used in the past in 

an attempt to minimize dangers presented during human 

interaction with these species. These procedures are not 

innocuous and can cause ongoing pain, discomfort, or 

other pathological conditions in the animals. In addition, 

they do not prevent predatory behaviors, safeguard the 

general public, or prevent biting in nonhuman primates 

and carnivores. 

The declawing of any wild or exotic carnivore does not 

constitute appropriate veterinary care. Any medical 

treatment of a paw should be limited to the affected 

digit(s) or area and should not require bilateral 

No Change

 

Change to: The declawing of any wild or exotic 

carnivore does not constitute appropriate 

veterinary care unless prescribed by the 

attending veterinarian for treatment of 

individual medical problems of the paws. Any 

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Animal Welfare Act

Summary Changes to Policy #3 – Veterinary Care 

declawing. 

 

The removal of the canine teeth of a nonhuman primate, 

or wild or exotic carnivore, unless for the immediate 

medical needs of the animal does not constitute 

appropriate veterinary care. 

 

Tooth reduction that exposes the pulp cavity does not 

constitute appropriate veterinary care as it may result in 

oral pathologic conditions and pain. Reduction that does 

not expose the pulp cavity may be acceptable in some 

instances such as a behavioral study or breeding 

situation. 

The American Veterinary Medical Association (AVMA) 

has developed a policy statement on these issues that 

supports APHIS’ recommendation. It also suggests 

alternatives to dental surgery such as behavioral

modification, environmental enrichment, and changes in 

group composition. A full text of AVMA policies can be 

found on www.avma.org.

medical treatment of a paw should be limited to 

the affected digit(s) or area. 

 

Change to: The removal of the canine teeth of a 

nonhuman primate, or wild or exotic carnivore, 

does not constitute appropriate veterinary care 

unless as prescribed by the attending 

veterinarian for the immediate medical needs of 

the animal.

No Change

No Change

Health Records

Health records are needed to convey necessary 

information to all people involved in an animal’s care. 

Every facility should have a system of health records 

sufficiently comprehensive to demonstrate the delivery 

of adequate health care. 

No Change

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Animal Welfare Act

Summary Changes to Policy #3 – Veterinary Care 

For traveling exhibitors, information on any chronic or 

ongoing health problems and information on the most 

current preventive medical procedures should 

accompany any traveling animals, but the individual 

medical history records may be maintained at the home 

site. 

Euthanasia

The method of euthanasia should be consistent with the 

current AVMA Guidelines on Euthanasia 

(http://www.avma.org/issues/animal_welfare/euthanasi

a.pdf), the American Association of Zoo Veterinarians 

(AAZV) Guidelines for Euthanasia of Nondomestic 

Animals or the European Commission Working Party 

documents (http://www.lal.org.uk/). 

Change to: The method of euthanasia should be 

consistent with the current AVMA Guidelines for 

the Euthanasia of Animals:

https://www.avma.org/KB/Policies/Pages/Eutha

nasia-Guidelines.aspx . 

Gunshot as a routine method of euthanasia endangers 

surrounding animals, buildings, and personnel, and it is 

likely to cause distress to other animals. 

It should only be used in situations where other forms of 

acceptable euthanasia cannot be used (such as 

emergency or field conditions where the animal cannot 

be appropriately restrained) or in cases where gunshot 

will reduce danger to other animals or humans. Only 

personnel skilled in the use of firearms, using appropriate 

firearms, and familiar with the "kill point" of an animal 

should perform the euthanasia. If the firearm is not 

aimed so that the projectile enters the brain and causes 

rapid unconsciousness and subsequent death without 

evidence of pain or distress, this method does not meet 

the definition of euthanasia. (All State and local laws 

relevant to gunshot must also be met.) 

No Change 

Change to: This method is conditionally 

acceptable under a specific set of circumstances 

in order to ensure the welfare of the animal 

undergoing euthanasia. Such circumstances 

include instances where other forms of 

acceptable euthanasia cannot be used (e.g. 

emergency or field conditions where the animal 

cannot be appropriately restrained) or includes 

situations where gunshot reduces the danger to 

other animals or humans. Only personnel skilled 

in the use of firearms, using appropriate 

firearms, and familiar with the "kill point" of the 

animal should perform the euthanasia. If the 

firearm is not aimed so that the projectile enters 

the brain and causes rapid unconsciousness and 

subsequent death without evidence of pain or 

distress, the definition of euthanasia is not met. 

However, it may not be appropriate to target the 

head when samples of brain tissue are needed, 

hence gunshot through the heart may be 

necessary in such situations. Note: All State and 

local laws relevant to gunshot must also be met.

Also note that in accordance with the "Expired Medical 

Materials" section of this policy, the use of expired 

euthanasia drugs is considered inadequate veterinary 

care.

No Change

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