Docket Number APHIS-2017-0102 Regulatory Analysis and Development PPD, APHIS, Station 3A-03.8
4700 River Road, Unit 118
Riverdale, MD 20737-1238
RE: Docket No. APHIS-2017-0102; Third-Party Inspection Programs under the Animal Welfare Act
On behalf of the accredited zoo and aquarium members of the Association of Zoos and Aquariums (AZA), I am writing in response to the recent request for comments on the possible use of third-parties for USDA/APHIS inspections under the Animal Welfare Act (AWA). We commend USDA for attempting to examine ways to streamline and reduce workloads for USDA/AWA inspectors but we are still unconvinced as to the need for such actions. If this action proceeds, we look forward to seeing further documentation as to how third party inspections would be certified and how those certifications would lead to a more efficient and effective AWA inspection process.
AZA is a non-profit organization dedicated to the advancement of zoos and aquariums in the areas of animal care and husbandry, conservation, education, science and recreation. AZA’s vision, and that of its member institutions, is to work with passion, leadership and collective action to understand and conserve the wonders of the natural world. 230 zoos and aquariums have met AZA’s strict accreditation standards to become members of the Association. AZA accreditation involves a thorough review and inspection process which examines all aspects of an institution’s operation, including the animal collection, veterinary care, physical facilities, quarantine procedures, safety, security, finance, staff, governing authority, support organization, education programs, conservation and research. AZA and its member institutions also work with Congress, the Federal agencies, conservation organizations, the private sector and the general public to conserve our wildlife heritage. With more than 200 million visitors to our accredited zoos and aquariums, AZA’s focus on connecting people and animals provides a critical link to helping animals in their native habitats.
While we understand and appreciate the agency’s desire to strengthen, and where appropriate, streamline AWA regulations pertaining to inspections, we are also acutely aware that unless specific procedures and protocols are succinctly defined and justified, they will become more cumbersome and inexact for the regulated community. It is critical for the agency to define the rationale for these actions and articulate the expected benefits to be derived. In the case of third-party inspection programs, AZA firmly believes that the current Risk-Based Inspection System (RBIS) is working fairly effectively and AWA inspections suffer more from a lack of financial and training resources for inspectors, inconsistent inspections, and unbalanced inspector workloads than anything else. While AZA greatly appreciates that APHIS/Animal Care has recognized the thorough AZA accreditation process as a positive factor when applying RBIS to the frequency of AWA inspections for AZA zoos and aquariums, we also welcome the opportunity to work with APHIS/Animal Care to increase the level of consistency on the part of AWA inspectors/inspections throughout all Class C licensed exhibitors. We are hoping to discuss this further with APHIS/Animal Care in the near future.
Should APHIS continue to pursue this third-party inspection initiative, I have attached copies of AZA’s 2018 Accreditation Standards and the 2018 Accreditation Guide for your reference. These documents will spell out what AZA inspectors, inspection teams and inspections should and must do throughout an AZA facility inspection.
In addition, in the past, we have proposed to USDA the establishment of a Class D license system which would include only those facilities that are accredited by a recognized professional organization which utilizes established professional standards and formal inspections in its accreditation evaluations. These standards must include a thorough review and inspection process which examines and documents all aspects of an institution’s operation, including the animal collection, veterinary care, physical facilities, quarantine procedures, safety, security, finance, staff, governing authority, support organization, education programs, conservation and research. We do not envision that Class D licensees would receive any preferential treatment from USDA through the inspection process but we do foresee Class D licensees as a reliable source for partnership, outreach, and externship opportunities for the agency. We stand ready to discuss this proposal further with APHIS at any time.
Thank you for the opportunity to comment on this very important matter.
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