Regulations and Standards

GAO Recommends Oversight of Random Source Dogs and Cats
On 24 September 2010, in response to decades-long public concerns that lost or stolen dogs and cats could be used in research, the Government Accountability Office: Natural Resources and Environment (GAO), published its report “Animal Welfare: USDA’s Oversight of Dealers of Random Source Dogs and Cats Would Benefit from Additional Management Information and Analysis.” In this report, the GAO evaluated and reported on “1) the number of random source Class B dealers, 2) the extent to which APHIS conducts inspections of these dealers and verifies their records, and 3) the costs associated with APHIS’ oversight of these dealers compared to other types of dealers.”

Random source Class B dealers generally obtain dogs and cats for research from individuals, pounds, and other dealers.

GAO Findings:

• Nine Class B dealers were licensed by APHIS in July 2010 to sell random source dogs and cats for research, well under the 100 or more such dealers in the early 1990s.
• Random source dealers sold 3,139 animals to research facilities in the period of November 2007– November 2008, or about 3 percent of the dogs and cats used in research in fiscal year 2008.
• There were numerous random source Class B dealer violations, such as the condition of animal housing and inadequate veterinary care. But APHIS has not completed or analyzed all of its fiscal year 2009 trace backs related to these dealers.
• In fiscal years 2007 through 2009, APHIS inspected, or attempted to inspect, each of these dealers at least four times a year. Fifty four of the 156 inspection reports cited at least one dealer violation, and seven of the nine dealers had one or more violations.
• By June 2010, APHIS successfully traced a dog or cat back to a legitimate source about 71 percent of the time, but 29 percent of the USDA’s trace backs were unsuccessful or not completed.
• Because APHIS does not analyze trace back data, it cannot systematically detect problems with trace backs and take all available steps to ensure random source dealers obtain dogs and cats from legitimate sources, e.g., whether the same sellers or inspectors were consistently involved in late or incomplete trace backs.
• APHIS does not collect, nor does it have a mechanism to determine the cost of its oversight of random source Class B dealers, or to any other class of dealer it inspects. Nor can it change its oversight program, if needed, to more effectively and efficiently use available resources.

GAO Recommendations to improve APHIS’ oversight of random source, Class B Dealers

The secretary of Agriculture should direct APHIS to:

• Improve the agency’s analysis and use of the trace back information it collects, such as whether the same sellers or inspectors were consistently involved in late or incomplete trace backs.
• Verify that random source Class B dealers are obtaining dogs and cats from legitimate sources, including making certain that trace backs are completed in a timely manner and conducted according to APHIS guidance.
• Develop methods to collect and track the oversight costs associated with the specific classes of dealers it inspects, including random source Class B dealers, in order to identify potential problems requiring management attention, and develop a business case for changing this oversight, if appropriate, to more efficiently use available resources.

“Animal Welfare: USDA’s Oversight of Dealers of Random Source Dogs and Cats Would Benefit from Additional Management Information and Analysis.” GAO-10-945. Government Accountability Office: Natural Resources and Environment, September 24, 2010. http://www.gao.gov/products/GAO-10-945 includes downloads of Highlights Page (PDF), Full Report (PDF, 25 pages), Accessible Text Recommendations (HTML)

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NIH Biomedical Research Facility Technical Criteria “News to Use”
Since April 2010, the Division of Technical Resources, Standards&Policy Branch, Office of Research Facilities,National Institutes of Health, has published “News to Use”—concise one page monthly articles for raising technical awareness of state of the art innovation, and the importance of attention to detail in designing highly complex biomedical facilities.

These NIH articles “condense important technical criteria in the Design Requirements Manual (DRM), and place emphasis on flexible design, safety and health of occupants, security, and protection of the environment. Each article guides the reader to the appropriate section of the DRM for additional topic detail.” See below for further information about the NIH Design Requirements Manual, issues of the News to Use, bio environmental studies, and biomedical and animal research facilities design policies and guidelines.