June 27, 2006
Docket No. APHIS-2005-0118
Regulatory Analysis and Development
4700 River Road, Unit 118
Riverdale, MD 20737-1238
RE: Docket No. APHIS-2005-0118: Proposed Rule on Shift Cage Requirements
On behalf of over 850 members of the American Association of Zoo Veterinarians (AAZV), I respectly submit the following comments in response to the APHIS proposed rule on shift cage requirements as published in the April 28, 2006 Federal Register. The comments below have been provided by our professional membership, and we appreciate the opportunity to provide our insight on this important issue.
This proposed amendment to the Animal Welfare Act intends to require the use of shift cages for handling certain species considered to be dangerous thereby mitigating escape of those animals, risk of human and animal injuries, and safe transport of the animals between enclosures.
AAZV would like to bring to USDA’s attention that not all species or individual animals can be trained to go into transport cages/shift cages or to shift off exhibits. Therefore, AAZV requests APHIS to include a statement in the regulations that recognizes that certain species or individuals cannot easily be trained for transfer into shift cages and to permit the use of alternative methods regarding the safe movement or shifting of certain animals but that still will address staff and animal safety.
AAZV would like clarification that these proposed regulations were not intended to limit or interfere with the need to anesthetize animals and transport animals under anesthesia, whether for routine husbandry purposes, medical procedures, or to off-site facilities for diagnostic or therapeutic procedures. Therefore, AAZV requests APHIS to include a statement clarifying the exemption of anesthesia from the proposed regulations. Moreover, AAZV requests APHIS to reiterate that written approval to move animals under anesthesia is NOT required. This provision would be overly burdensome and require unnecessary administrative paperwork.
AAZV understands that the proposed regulation addresses movement of animals between enclosures within the zoo facility but would like clarification as to whether this also would apply to animals transported to and from the zoo veterinary hospital and their enclosure on the zoo grounds. Many animals may require short-term treatment or hospitalization and are immobilized to go back to their exhibit or holding facility. Also animals may be immobilized for the purpose of transferring from one holding facility to another. If all zoo veterinary hospitals will be required to have shift facilities compatible with transfer cages for movement around the zoo, this would be a significant impact on hospital design, with resultant financial burden to the facility. Therefore,
AAZV requests APHIS to include a statement clarifying that shift cages are not required within the zoo veterinary hospital if animals housed in the hospital will be immobilized for transport to and from the hospital and their enclosure.
Furthermore, the addition of shift cages to certain zoo areas or structures may require that the fixtures be such that the crates can be removed when not in use and perhaps even transported to other areas of the zoo as needed, rather than incur the expense of a permanently fixed structure for every exhibit . Some areas may need significant modification incurring major expense for the zoo in order to accommodate shift cages. Therefore, an alternative method to meet these requirements should be devised and timeline for modifications, if required, should be included in the regulation. Space limitations may preclude the ability to make these modifications, so a method for granting waivers should also be considered.
AAZV would like clarification that these proposed regulations will apply to intra-zoo transfers only (movement of animals within the zoo facility) and will not alter or modify the current inter-zoo transfer regulations.
AAZV has some members that are employed in research institutions who would like clarification on whether this proposed shift cage requirement would prohibit the use of pole and collar system used by many research institutions when transferring awake research monkeys from their home cage to a test apparatus. Movement via pole and collar was developed more than 20 years ago as an alternative to maintaining monkeys continuously in a training apparatus for weeks to months at a time. The pole and collar system has proven itself to be a safe method [for humans and monkeys] to allow this type of neuroscience research while posing the least risk of morbidity for the monkey. Cages in the research institutions commonly have tunnels or moving panels to allow movement between cages for routine cleaning but movement from a cage to a recording apparatus would appear to also be covered by this rule. Therefore, AAZV requests APHIS to consult with the appropriate professional organization that represents primate laboratory facilities to determine if a statement indicating that the use of the pole and collar to move awake primates within research settings may be a valid alternative to a cage shift for those expressed purposes.
In summary, the AAZV opposes the proposed rule as it is currently written since it does not make animal movements more efficient, safe or effective than methods that are currently used by our professional members. The proposed rule will place a significant logistical and financial burden on our member facilities without increasing the safety of the operations. Animal dealers or exhibitors that operate unsafe methods of animal transfers should be educated and trained to use appropriate means of animal handling rather than regulate all facilities.
Thank you for the opportunity to comment on this issue.
Michele Miller, DVM, PhD
AAZV President 2005-06