Wild Stewards

I believe one of the best things to improve animal welfare is to share relevant and understandable information with people. Unfortunately, many zoos struggle with this as it’s so easy for them to become inwardly focused and disconnected. Understandably, zoos are set up more for guests to be spectators than connected participants. This widens the gap between animals and everyday people that are only getting wider as people’s connection to the natural world shrinks.

Being outside of the zoo community right now has given me a new perspective of both worlds. One of my goals with this blog is to help make animal information applicable and understandable to hopefully bridge that gap. I don’t want to tell people what to think but hope to give tools to understand why and then how to apply this information to all become better animal caretakers and advocates. 

People today hold strong opinions and views of what they feel are acceptable and not acceptable standards when it comes to animal welfare. Unfortunately, many zoos can leave people confused or even sad about their animal welfare standards and practices. A big part of this confusion or sadness comes from guests’ perception that their feelings are what indicate good or bad animal welfare. How will these emotions and feelings change unless people become more educated and connected?

One of the ways we can help is to share what goes into running a zoo and caring for all the animals. Also, educating every guest that they can be a part of that equation and have a voice in the welfare of zoo animals. I hope to give you some tools, that are available to everyone, on what you can do if you see something you feel is wrong or inadequate during a zoo visit. 

Are you aware that there are minimum standards every zoo in the United States must uphold? To help you understand this, I will zoom out and provide a brief overview and simplification of some rules and regulations that all “zoos” are required to uphold. Then my goal is to provide some tools available for you to use. Please take note that this is by no means a complete view of this topic but an overview of broad concepts. 

Why Animal Regulations

The first Federal legislation passed by Congress was not until the 1960’s. It took years and years of hard work and lobbying before the federal government stepped in and provided some rules and regulations for animal use. The public outcry mostly over animals being used for research was the driving force for this legislation. The use of animals in research was gaining momentum in conjunction with the growing advances in the medical field but its oversight was not. 

Before the ’60s, institutions that used animals in their research had very little to no Federal regulations and oversight for their treatment of animals. As this demand for laboratory animals grew so did journalistic stories from big names such as Sports Illustrated and Life Magazine. Their stories pulled at the public’s heartstrings. Crazy, but true, depictions of pets being stolen out of people’s backyards as well as pictures of horrible breeding mills selling these animals to research facilities were often front page. 

Something had to change. The government’s answer was to create the Laboratory Animal Welfare Act in 1966. Out of this came many additions and amendments over the years for animal care oversight on a federal level. This act gave the federal government jurisdiction to impose minimum standards for animals commonly being used for animal testing. This evolved over the decades to become what it is today… the current Animal Welfare Act (AWA). The Horse Protection Act, the Marine Mammal Protection Act, and the Endangered Species Act were also born out of this. 

One thing to know and understand, the Animal Welfare Act only regulates certain animal species. They only regulate and have jurisdiction over warm-blooded mammals and newly added birds. Reptiles, insects, fish, etc. are not covered and standards can not be enforced. As a government agency, it takes years to revise, update, and then enforce these additions as they just completed to include birds. Regulating birds was put into effect on February 2023. If you’ve ever wondered why there seem to be more traveling reptile shows there is a simple answer, they are not regulated. Birds have been added, but it’s the government we are talking about here, so it is not an easy or simple process. 

Who is regulating?

Congress appointed the United States Department of Agriculture (USDA) oversight over the Animal Welfare Act and gave the Animal and Plant Health Inspection Service (APHIS) agency jurisdiction over the enforcement. APHIS has qualified government officials, usually seasoned veterinarians, who carry out the inspection and enforcement. These inspectors are solely responsible for the oversight and enforcement of the Animal Warfare Act. Inspectors are held to high standards as government officials and you can read their guidelines on the link below. APHIS inspectors do not have an easy job. In the United States, there are over 13 thousand licensees representing over 1.4 million animals.  

Please note, that there can be additional factors that oversee certain animal practices such as state-level Fish and Wildlife restrictions, any accreditation association standards, as well as possible city/county regulations (I will not be covering that now).

https://www.aphis.usda.gov/animal_welfare/downloads/Animal-Care-Inspection-Guide.pdf

Who is regulated, and who is not?

Remember, the Animal Welfare Act only regulates and enforces mammals and birds (birds added 2023). 

Animal Dealers 

Class A – Deals (sells or trades) only regulated animals that they breed or raise (breeders & sellers, not brokers)

Class B – Obtain and sell regulated animals that they did not raise (brokers & not breeders)

Exempt – retail pet stores, individuals selling all animals directly, and hobby breeders (exceptions apply)

Transporters

Commercial businesses that move and/or transport regulated animals

Researchers

Institutions that use regulated animals in/for research

Exhibitors

Class C – Anyone who displays regulated animals to the public for compensation (can breed and/or broker animals but not a main focus)

There is a wide range of institutions, organizations, and even individuals that fit into this category. When my husband and I ran our animal outreach company we were licensed and regulated as a Class C exhibitor. 

Who’s regulated – Zoos, museums or educational/nature centers that display mammals, outreach companies, circuses, sanctuaries that exhibit animals, petting zoos, etc

Exempt – Agriculture, horse shows, pet shows, game preserves, hunting, private collections that do not exhibit

How can I find who’s regulated?

A complete government-run online database of everyone licensed is available for all to view online. You can find this information using the USDA Animal Care Public Search Tool. This tool is fairly user-friendly and allows you to see a complete and up-to-date list of who’s licensed. If you have trouble figuring out how to navigate this tool they provide you with a PDF guide as well as a demonstration video. You can search by many functions such as by name, state, or city to see who’s licensed, and who’s not. 

Most people are unaware that they can also view inspection reports online as well. While this is not going to show you everything, it can give you a small glimpse into the quality of these facilities. Anyone who’s licensed under the Animal Welfare Act is required to be inspected unannounced to make sure they are maintaining the standards and in compliance. 

I would like to add I hope I am not painting a harsh or bad image of the zoo community. I am a supporter of zoos and think they do amazing work caring for animals and are leaders in animal conservation. At the same time, just like every field, there can always be growth. This information is to hopefully give you a better appreciation for all that goes into running a proper zoo. This understanding will hopefully allow you to have a more positive view of zoos and give you confidence in their animal care procedures.

https://aphis-efile.force.com/PublicSearchTool/s/

What standards must be upheld?

Remember, I am providing a very broad and simplified overlook. I will simply list some of the criteria all are required to uphold when using mammals for profit. Remember the government provides MINIMUM standards one must uphold so even a facility that upholds these standards does not imply good animal welfare. 

• Housing and Facilities (overall)
  • should be structurally sound
  • In good repair
  • Are to be free from mold and/or rust
  • Free from excessive cobwebs and/or weeds
  • Free from accumulation of trash or waste
• Animal enclosures 
  • Must safely contain animals
  • Protect them from harm
  • Shall be constructed and maintained to provide sufficient space
  • Allow each animal adequate freedom of movement
• Proper drainage in habitats
  • No standing water or puddles (in places not intended for water)
  • Animals should be able to keep dry and free from harm
• Ventilation 
  • Proper ventilation to minimize odors, drafts, ammonia levels, and moisture condensation
  • If ambient temperatures are over 85F or under 45F heating, cooling, or increased ventilation shall be provided
• Lighting
  • Gives animals proper lighting cycles
  • Is uniformly diffused
  • Lit well for the safety of animals and staff
  • Animals should have a place to retreat from excessive light if wanted (such as den boxes)
• Habitat surfaces
  • Surfaces are impervious to withhold moisture 
  • Properly maintained (fee from chipping and damage)
  • Surfaces can be easily cleaned and sanitized
• Sanitation
  • Animal waste must be removed and disposed of as necessary
  • Habitats shall be sanitized at least every two weeks 
• Pest Control
  • Must develop and maintain an effective pest control system
• Feeding
  • Animals shall be provided with nutritious and palatable food
  • Food must be free from contamination, properly stored, and served in a clean receptacle
  • Animals shall receive their full dietary/nutrition for the day (no deprivation)
• Water
  • Potable water should be available at all times
  • If animals are traveling, working, or at shows water shall be offered as necessary for the species’ needs
• Outdoor shelter
  • If animals are housed outdoors they should have access to shelter that provides them from sunlight, precipitation, and extreme temperatures
  • A perimeter fence must be intact (to keep facility animals in and wild animals out)
• Compatibility
  • Animals shall be housed in appropriate groupings and with compatible species
• Storage
  • Animal food, bedding, and supplies are to be stored in a manner that protects them from spoilage, contamination, and vermin
• Animals used in shows
  • Performing animals must be allowed time to rest between shows for at least equal the amount of time used in the shows
  • Young or immature animals shall not be exposed to rough or excessive public handling
  • Drugs shall never be used to facilitate handling and/or exhibiting
• Animal handling
  • Must be handled properly at all times by employees with adequate experience and knowledge
  • No physical abuse or neglect of any kind
  • If the public is allowed contact with animals a responsible, knowledgeable, and readily identifiable employee must be present
  • Wash stations shall be provided after animal contact
• Organizational and administration things behind the scenes (you won’t see)
  • Records on animal acquisition, health, and identification shall be accurate, complete, and up-to-date
  • Contingency plans shall be provided for potential animal issues as well as natural disasters
  • Program of Vet Care must be established and maintained every year
  • An attending Veterinarian must oversee and be given authority
  • Records kept of daily behavioral enrichment for certain animals such as primates, dogs, and marine mammals. 

What does this mean practically?

Now that you are aware of some minimal standards that must be upheld for anyone licensed under the Animal Welfare Act, what can you do with this? What most people don’t know, and the purpose of this blog post… since these, and many more not listed, standards must be upheld for any animal facility anyone can file a concern or complaint if they see unmet standards. APHIS Inspectors are very busy and cover wide territories, they can only catch so much. Depending on the type of facility as well as the length of licensing, inspectors are only required to inspect yearly on average. But if valid complaints are made it’s their job as overseers and enforcers to follow up and follow through. That means you can be a valuable part of making sure animals are receiving good care. 

Please take note, I’m not suggesting you start filing a complaint for everything you see if you just don’t like a certain zoo. But if you see or experience something, you can, and probably should, file a complaint. If you see something that you believe puts an animal’s life in danger or impacts their welfare negatively make sure you mention it to employees there first, that is obviously the right thing to do for the animal. But you can still make a report if you would like. You might even want to include the employee’s name and reaction to how they handled a situation in your report.

How to make a complaint

So how can I share a concern or make a complaint I might have? 

One way would be to call the USDA-APHIS Center of Animal Welfare Office (or your local regional office). When my husband and I owned our animal outreach company most of our traveling animal crates had large USDA stickers that had this number on the side, we were not hiding anything. We were aware of, and wanted others to be aware of as well, that there were standards we needed to maintain and were accountable to follow. To my knowledge, we never received any concerns or complaints from anyone to the USDA.

https://www.aphis.usda.gov/aphis/banner/contactus/sa_animal_welfare

An easier way for most of us is to use their simple online form. This is often a better way, unless an animal’s life is in danger, as it allows you to record any details and explanations and leaves a written trail. Anyone can at any time file an online concern. You have the option to submit it anonymously or not. For example, if you work somewhere and there is an issue that is not being corrected or you feel an animal’s welfare is in jeopardy you can file anonymously. Let’s face it, it’s unfortunate, but often things won’t change until someone (in control) is caught or called out. 

https://www.aphis.usda.gov/aphis/ourfocus/animalwelfare/complaint-form

If you choose to leave your personal contact information when filing you will be able to be reached if more details are needed. But keep in mind that while your information will be kept private the licensee has the right to submit a form (Privacy Act) that would allow them to access both your complaint and your identity. This is to protect the licensee from someone who is out to get them or personally attacking and making up falsehoods. You are also granted rights through the Freedom of Information Act (FOIA) to submit a form to learn about the outcome of your concern. 

Important details to remember

• The date and time
• Facility/organization/institution name (license # if possible but not needed)
• The location of the incident
• Types of animals present or involved
• Names of any employees if applicable 
• Pictures (so important if possible)
• The behavior and/or condition of animals
• The condition of the facility
• Employee or owner reaction to your concern(s) (or if you told anyone or not)

Examples of complaints and/or concerns that you should file

(Some of these are made-up scenarios although most are actual citations)

• A primate is seen with a visible limp and in pain, you look around for someone to tell but see no one (or you are able to tell). At the end of the day, you go back to the habitat and see the animal in the same condition. (*required to notice, communicate effectively, handle the situation, and record medical issues in a timely manner)
• There is a standing puddle of water on a concrete surface in an animal’s habitat. The staff did not drain or squeegee the water away. (*Proper drainage required)
• You are in a kangaroo walkabout (in their habitat) and you do not notice any staff present, they are not easily identifiable or are overly distracted such as talking to other staff for a length of time or on phones (*Staff must be present, responsible, knowledgable, and easily identifiable at all times guests have contact with regulated animals)
• Animal habitats are in poor condition. You notice excessive rust or mold, electrical wires in animals’ reach, habitats falling apart or breaking, areas where animals can hurt themselves, or etc (*Animals are to be housed in sound conditions)
• A wild rat snake was found in a bat enclosure. The enclosure is mesh with 1 inch openings that the snake was able to enter the enclosure through. A wild alligator was found in the cheetah exhibit. There is an area of the enclosure that the alligator is believed to have climbed onto and then fell or jumped into the enclosure. I’ll note that this was an actual citation for a zoo in the South. No cheetahs were injured but a bat was eaten by the snake (*Housing facilities must be constructed and maintained to protect the animals from injury, including from predators that access the enclosure)
• The dig barrier around the enclosure for the fossa is approximately 30 inches wide and runs the length of the enclosure walls. On the front and right side of the enclosure, the dirt beneath the dig barrier has washed out or eroded leaving the chain-link dig barrier exposed and raised with gaps between the barrier and the dirt. These gaps create a safety hazard that may allow the fossa to become injured when running or crosses over it. (*This is an enclosure safety hazard for the fossa which could lead to possible injury) 
• In an outdoor enclosure housing 2 elands, the flooring leading to the waterer was significantly muddy with a honeycomb appearance and some standing water. The animals had to walk through the mud in order to access their drinking water. (*Enclosures need to drain effectively and animals need to be able to access water sources easily)
• The ceiling of the Rhinoceros indoor barn had an excessive amount of spider webs. A large amount of dust and debris was interspersed within the webs. (*Sanitation issue)
• The vent above the enclosure in one of the holding rooms of the hospital area was significantly coated with dust and debris. On the ceiling in a circle around the vent, a gray layer of dust and debris could be seen. These areas are not being maintained in a manner that protects animal health and welfare. (*Sanitation issue as facilities must be kept clean in order to protect the animals from injury, to facilitate the required husbandry practices and to reduce or eliminate breeding and living areas for rodents, pests and vermin)

Thank you for reading this blog. I hope it gave you some great tools and insights into some of the regulations that are upheld for animal organizations or businesses. We can all be a part of a positive growth and change for the animal industry. I hope you use this information wisely and in a constructive and helpful way. There are check-and-balances in place, although small, and you can help hold these facilities accountable to these federal standards. A facility that truly cares for animals is transparent, open for correction, and takes concerns seriously (regardless of who it’s from). But remember to give some grace. There is a lot in our culture fighting against zoos already. Zoos at the end of the day are a business that rely on money in order to pay staff and care for the animals they house. I personally know almost everyone in the animal community truly wants to do the best job possible. They do what they do because they love animals and love what they do. The ultimate goal is the best welfare of animals. 

I would love to hear from you! Feel free to message me below.