For decades, animal dealers have been providing dogs and cats to scientific researchers. Within this broader group, random source Class B dealers are those who provide dogs and cats that they obtain from pounds, shelters, auction sales, or owners who breed the animals on their premises. For certain research, some attributes of random source dogs and cats are considered useful and desirable, such as particular physical or genetic characteristics or the presence of specific diseases or conditions. For example, according to a study conducted by the National Research Council and information from the National Association of Biomedical Research, random source dogs tend to be 2 years or older, tend to weigh from 60 to 80 pounds, and may be of mixed breeds. These attributes make them useful for cardiovascular, pulmonary, orthopedic, and age-related studies. Random source cats are considered useful for neurological and cardiovascular research and studies on respiratory diseases and the immune system. In addition, random source dogs and cats are considered useful for the study of certain naturally occurring infectious diseases, such as Lyme disease and heartworm, or as animal models for human diseases, such as sleep apnea and muscular dystrophy. AWA provisions cover a variety of animals, including any live or dead dog, cat, nonhuman primate, guinea pig, hamster, or rabbit to be used for research, testing, exhibition, or kept as a pet. AWA requires businesses or individuals covered by the law to be licensed or registered and to uphold minimum standards of care set in regulation. Licensing and registration under AWA is based on broad business categories, including animal dealers, animal exhibitors, animal carriers, and research facilities. Animal dealers and exhibitors are required to be licensed, while animal carriers and research facilities are required to be registered. There are two types of licenses for dealers—Class A and Class B—and one type of license for exhibitors—Class C. Class A licenses are specifically for animal dealers who only deal in the animals they breed and raise, while Class B licenses are for all other types of dealers and include the purchase and resale of any animal covered by AWA. Class C licenses are for businesses or individuals whose business involves displaying animals to the public. According to APHIS information, in fiscal year 2009 there were a total of 9,530 facilities licensed or regulated under AWA, which consisted of 3,898 Class A dealers, 1,031 Class B dealers, 2,732 Class C exhibitors, and 1,257 research facilities, among others. The APHIS Animal Care program administers the requirements of AWA and its implementing regulations. APHIS Animal Care undertakes a variety of AWA regulatory activities, such as the licensing and registration of facilities with animals covered by the act, unannounced compliance inspections of licensed and registered facilities, and investigating public complaints. In addition, Animal Care administers activities related to the Horse Protection Act and has a role in planning and coordinating disaster response efforts for household pets. In fiscal year 2010, the Animal Care program had an annual budget of approximately $22.5 million and a staff of 209, including about 100 field inspectors, who report to either of two APHIS Animal Care regional offices. The APHIS field inspector cadre is about evenly divided between veterinary medical officers, who hold veterinarian degrees, and animal care inspectors, or technicians. Eight field inspectors are assigned to random source Class B dealers, and five of them are veterinary medical officers. Inspecting regulated licensees’ and registrants’ facilities, which include random source dealer facilities, is the primary way APHIS Animal Care ensures compliance with AWA. All inspections are unannounced, and generally the owner or manager of a facility accompanies the inspector during the inspection. The time required to conduct inspections varies and is affected by facility size and the number of regulated animals involved, among other things. The inspection process consists primarily of two parts—a physical inspection and a records inspection. During the physical inspection, the inspector observes and documents the condition of the facility and the animals in the facility to ensure the dealer is adhering to AWA. The physical inspection may also involve the inspection of transportation devices, such as vehicles and shipping containers for animals, if necessary. During the records inspection, inspectors review records that dealers are required to maintain to ensure they are accurate and complete for all animals the dealers have obtained or sold. Random source Class B dealers are generally required to comply with the same regulations as other licensed Class A or B dealers. As such, when APHIS inspectors inspect these dealers, they are to ensure that they, like other dealers, are providing appropriate and adequate veterinary care; properly tagging or identifying animals; maintaining accurate records; and complying with standards of humane care, treatment, handling, and transportation of animals. However, APHIS guidance imposes additional controls on random source Class B dealers, and inspectors are directed to (1) perform quarterly facility inspections, which are more frequent than for any other dealers, and (2) use dealer records to conduct tracebacks by tracing a particular dog or cat back to the source from which a dealer obtained the animal, both to verify the legitimacy of the sale and ensure the dog or cat was not lost or stolen. APHIS determined that more frequent inspections were required for random source Class B dealers because they are higher risk than other types of licensees. APHIS inspectors are to conduct tracebacks within 30 days after each inspection by tracing some of the dogs or cats a random source Class B dealer obtained back to their sources. Specifically, an inspector randomly selects 4 to 10 of the dogs and cats acquired by the dealer since the last quarterly inspection. Inspectors then are to use the dealer’s records on these selected animals to conduct tracebacks by either (1) visiting the seller listed on the dealer records or (2) if the seller is a pound, shelter, another licensed dealer, or an individual already known to the inspector, contacting them by telephone. During the visit or telephone call, inspectors are to obtain specific information from the seller to determine if the sale was from a legitimate source. For example, if an inspector conducted a traceback on a dog sold by an individual to a random source Class B dealer, the inspector would attempt to confirm that the requirement that the dog be bred and raised on the individual’s premises is met. Once the traceback information is obtained, the inspector completes a traceback worksheet form, documents the traceback result, and forwards the completed form to the appropriate APHIS regional office. If, however, an inspector is unable to perform a traceback because the seller is outside of the inspector’s geographic area, the inspector sends the incomplete traceback to the appropriate APHIS regional office. The traceback is then ultimately referred to an inspector who has responsibility for the area in which the seller is located. In these cases, inspectors are directed to complete referred tracebacks within 30 days of receiving the traceback request. Recently, the USDA Office of Inspector General completed an audit of the APHIS Animal Care program and reported several concerns related to APHIS inspections and enforcement. The Inspector General’s May 2010 report found, among other things, that APHIS was ineffective in dealing with problematic dealers and that some inspectors did not cite or document violations properly. The report primarily focused on Class A dealers who breed and sell dogs. The Inspector General chose these dealers in part for their large facility size and the number of violations, or repeat violations, that they received during fiscal years 2006 through 2008. According to Inspector General officials, no random source Class B dealers were included in this study. APHIS concurred with the findings and recommendations in the Inspector General’s report and has taken several actions to respond to the recommendations. Among them, the agency developed an Enhanced Animal Welfare Act Enforcement Plan in May 2010, which provides details on how the agency plans to focus its enforcement efforts on problematic dealers and improve inspector performance, such as by providing additional training and guidance to inspectors and their supervisors. APHIS also provided a new Inspection Requirements Handbook during the April 2010 national meeting it held with all of its Animal Care inspectors and regulatory staff in anticipation of the Inspector General’s report, along with training on inspection enforcement and consistency. Additionally, APHIS redirected funding in June 2010 to provide an extra $4 million to help implement steps in the enforcement plan and proposes using this funding to, for example, hire additional Animal Care inspectors and supervisors (up to 60 additional personnel total). Though none of these actions were explicitly directed at random source Class B dealers, the new handbook contains some relevant supplemental information, including the previously released July 2009 Standard Operating Procedures for Conducting Tracebacks from Random Source B Dealers, which generally directs that tracebacks be conducted within 30 days of an inspection. As of July 2010, there were 9 Class B dealers licensed by APHIS to sell random source dogs and cats for research. This number has changed little since the end of fiscal year 2005, when APHIS reported there were 10 active random source dealers. Eight of the 9 active dealers are in the APHIS Eastern Region, and 1 is in the APHIS Western Region. Overall, the number of random source Class B dealers has fallen by over 90 percent since the early 1990s, when there were over 100 such dealers licensed by APHIS. APHIS officials attributed the decline to several factors, although they said the agency has not performed a detailed study of this matter. These factors include (1) the reduced use of random source dogs and cats by research institutions due to new technologies and computer modeling; (2) increased pressure from animal advocacy organizations to use purpose-bred dogs and cats for research; and (3) APHIS’s oversight and issuance of citations for AWA violations, which has led some dealers to leave the business. The use of dogs and cats in research has dropped significantly over the last 30 years.