by Michelle C. Pardo
The United States Department of Agriculture (USDA) has extended the deadline for submitting comments to an advance notice of proposed rulemaking (ANPR) on standards for handling captive wild and exotic and animals and changes to environmental enrichment requirements for all regulated species.
Stakeholders will now have until April 10, 2023 to submit comments.
The ANPR is available to view and comment at https://www.regulations.gov/document/APHIS-2022-0022-0001.
USDA’s Animal and Plant Health Inspection Service (APHIS) has requested comments in three particular areas:
- Public handling of wild and exotic animals at licensed exhibitor facilities;
- Training of personnel who handle wild and exotic animals at licensed facilities; and
- Changes to regulated animals’ environments to promote their psychological well-being.
Participating in the comment process is essential for regulated stakeholders, as agencies must consider all “relevant matters presented” and respond in some form to comments received in formulating their rules. If opposition is exceptionally voluminous or strident, an agency may decide to publish a new notice and/or establish a new comment period.
All perspectives are helpful, but keep in mind the following:
DO attempt to respond to the questions asked by the agency. Additional material may be appropriate to include, but try to at least provide the agency with guidance on the requested topics.
DO highlight the financial ramifications to your facility with any significant additions or changes to the regulations. For example, would increased regulations demanding a certain type of training program or experience erect an impractical barrier to staffing? Are certain formal training programs less effective than apprenticeships or on-the-job training? Would such regulations practically require “form” over “substance”?
DO provide comments on whether more particularized regulations on animal enrichment would unnecessarily limit an exhibitor’s ability to provide effective enrichment to their animal populations. Would regulations diminish the ability to be innovative about the nature and type of enrichment? Would they lag behind science and research and therefore create worse, and not better, animal welfare circumstances?
DO describe in detail any unintended, negative effects that further regulation can produce, either to the well-being of particular species or a licensed facility’s ability to practically care for its animals.
DO include “myth-busting” in your comments that call out speculative and philosophical-driven theories of animal welfare and pseudo-science that are not backed by science and research. Include peer-reviewed research or other resources that supports your comments or successful anecdotal cases that are relevant to the issues.
Most importantly, do not assume that another exhibitor will represent your particular interests. Participate and influence regulations that affect your businesses and organizations.