LIOC-ESCF : Legal : Big Cat Guidelines

Endangered Species Conservation Federation

USDA Proposed Draft Policy on Training and Handling of Potentially Dangerous Animals

USDA published it's intent to clarify policies concerning trainer and handler experience and the safe handling procedures required for potentially dangerous animals in the July 24, 1997 issue of the Federal Register. Over 400 comments were received, some included copies of training manuals used by various facilities. Based on the public comments and the experience of the Animal Care inspectors who enforce the Animal Welfare Act, a draft policy was formulated to clarify existing regulations to help ensure safe and humane handling of animals in exhibits.

USDA Animal and Plant Health Inspection Service published their Draft Policy on Training and Handling of Potentially Dangerous Animals in the Federal Register on February 18, 2000. (Volume 65 Number 34) and requested comments from interested parties. LIOC Endangered Species Conservation Federation submitted written comments, and those follow this policy summary.

The complete Draft Policy on Training and Handling of Potentially Dangerous Animals statement can be accessed on the internet at http://www.aphis.usda.gov/ppd/rad/webrepor.html. For further information contact:

Dr. Barbara Kohn, Senior staff Veterinarian
AC, APHIS
4700 River Road Unit 84
Riverdale, MD 20737-1234
Tel (301)734-7833

USDA efforts to standardize their interpretation and enforcement of the Animal Welfare Act in regards to the exhibition and training and handling of potentially dangerous animals and the personnel who perform these duties is still not finalized. But most of the items outlined in the draft policy are already being enforced by inspectors, so Class C Exhibitors of wild felines should be prepared to document the various requirements outlined in this summary below.

The draft policy statement addresses three issues:

Personnel
Handling Techniques and Procedures
Contingency Plans

Personnel Training

The handler should have demonstrable knowledge and skill in the currently accepted professional standards and techniques in animal training and handling and in the husbandry and care requirements of the species being exhibited. USDA requires primary handlers to possess a minimum of 2 years handling experience in the species being exhibited, with at least one year experience in public contact situations.

Handling Techniques and Procedures

USDA clarifies what constitutes physical harm or behavioral stress in animals. Several examples are:

Excessive environmental noise
Excessive crowding around the animal
Inappropriate age of the animal (too young or too old)
Failure to maintain flight (escape) distance
Lifting animals by their limbs
Too many or too long interactive sessions
Threatening or aggressive postures or movements by other animals or persons

USDA will closely scrutinize situations where animals over 75 pounds or 4 months of age are used in close contact situations such as photo booths. And no animal with a prior history (including even a single incident) of aggressive and uncontrolled behavior should be used for this purpose.

Contingency Plans

Contingency Plans which address emergency situations should be designed to minimize risk to the animals and the public. They should cover, but not be limited to:

Procedures for handling and recapturing escaped animals, equipment to be used, people to be contacted, and the chain of command.
Criteria for deciding when to use various restraint methods and identification of the person who is responsible for making such a decision.
The level of force used, up to and including lethal force, should it be consistent with the situation.
Provisions for when to contact local law enforcement.

Further the availability and appropriate use of any or all of the following emergency equipment should be considered in a contingency plan.

CO2 fire extinguishers
High Pressure fire hoses
Pepper spray
Darting equipment
Radios
Cell phones
Crowd Control fencing
Capture nets

LIOC Endangered Species Conservation Federation's Written Comments Submitted to USDA

This is a policy to help clarify the rules which govern exhibiting potentially dangerous animals. But the USDA only loosely defines this category of animals as elephants, bears, big cats, wolves and nonhuman primates. The LIOC-ESCF feels that this a major oversight, and the USDA needs to clarify exactly what they mean by the term "big cats". Is it any cat bigger than a housecat, or is it just the panthera species? Let's not leave it up to the individual inspector to interpret.

Also the USDA needs to clarify what it means by "potentially dangerous". Is a 2-year old, 35 pound serval potentially dangerous? If so, licensed Class C exhibitors with less than 2 years handling experience with their feline species, and less than 1 year experience with exhibiting this species could be found non-compliant, should they exhibit.

Further, we question the experience requirement need specific to each species. Each genus perhaps, but persons with multiple year's experience with lions should not have to demonstrate the two years handling experience to exhibit a young tiger. The same applies to the smaller species of cats, in the event that they be classified as potentially dangerous.