Strategic Direction for the

Animal Care Program

January 2000

U.S. Department of Agriculture
Animal and Plant Health Inspection Service


Executive Summary

The U.S. Department of Agriculture (USDA) is committed to carrying out its responsibilities and meeting public expectations in enforcing the Animal Welfare Act (AWA) and the Horse Protection Act (HPA). USDA enforces these acts though the Animal and Plant Health Inspection Service's (APHIS) Animal Care (AC) program area. APHIS conducts inspections and requests investigations into violations of these acts, and works with the Department to prosecute violators.

APHIS is continually evaluating the effectiveness of its AC programs and activities. In April 1996, APHIS first published the Strategic Direction for the Animal Care Program. This Strategic Plan also included the Horse Protection Program. In 1997, a separate strategic plan was developed for Horse Protection. The January 2000 Strategic Plan is solely reflective of the program supporting the Animal Welfare Act, follows the format of the 1996 plan, gives updates of ongoing activities supporting the original tenets and initiatives, and offers suggestions for improving the program. These tenets are:

The issues facing AC can be placed into four categories: dealers and exhibitors, research, transportation, and resources. Issues with regulated entities include effectiveness of penalties, pet theft, license renewal for chronic violators, nonhuman primate enrichment, and identification of dangerous exhibited animals. Resource-related issues include cost increases under static appropriations, public understanding and awareness, and adopting industry standards.

Methods of addressing these issues include clarification of regulations, innovative enforcement, increased field employee involvement, enhanced external partnerships, and concentrated outreach, education, and communication activities. Examples of these methods include the Risk-Based Inspection System (RBIS), the Technical Advisory Group (TAG), specialized training in areas such as elephant handling and dog breeders, the research preceptorship, policy statements, and tracebacks on animals sold into research.

CONTENTS

I. Introduction 1

II. Issues Facing Animal Care

3
      A. Dealers and Exhibitors
    3
      B. Research
    4
      C. Animal Transportation
    5
      D. Resources
    5

    III. Improvement Initiatives

    7
        A. Enhance Statutory, Regulatory and Procedural Authorities
      8
        B. Encourage Excellence in Animal Care
      11
        C. Maximize Resources for Enhanced Program Delivery and Efficiency
      14
        D. Respond to External Concerns and Expectations through Objective Action
      16
        E. Empower, Support and Develop Employees
      18

      IV. Appendices

       

        A. 2000 Animal Care Strategic Direction Team
      21
        B. Proposed Legislative and Regulatory Changes
      22

      I. Introduction

      The U.S. Department of Agriculture's (USDA) Animal and Plant Health Inspection Service (APHIS) is committed to carrying out its responsibilities and meeting public expectations in its enforcement of two laws that seek to ensure the humane care and handling of animals: the Animal Welfare Act (AWA) and the Horse Protection Act (HPA). The AWA sets minimum standards of care and treatment for most warm-blooded animals bred for commercial sale, used in research, transported commercially, or exhibited to the public. The law was first passed in 1966, and was amended in 1970, 1976, 1985, and 1990.

      USDA enforces these laws through APHIS' Animal Care (AC) unit, which is headquartered in Riverdale, MD. Three regional offices in Raleigh, NC, Fort Worth, TX, and Sacramento, CA, are charged with enforcing the AWA and HPA in each of their respective regions. Each regional office employs field veterinary medical officers (VMOs) and animal care inspectors (ACIs). These employees are highly qualified, and have an excellent professional support system and communication network. Many also have specialized interest and expertise in such areas as the care of laboratory animals, zoo animals, or marine mammals.

      Mission

      The mission of AC is to provide leadership in establishing standards of humane care and treatment of animals, and to achieve compliance with those standards through inspections, education, and cooperative efforts.

      Philosophical Direction

      AC is guided by principles that the Animal Care Management Team provided to employees in a January 1998 memo.

      The purpose of the Strategic Direction for the Animal Care Program (Strategic Plan) is to define the challenges that face the program and propose strategies for improvement. Elements of this plan may be incorporated into other documents, and used to guide decision making and operations in coming years. The activities shown under the tenets explained in Chapter III embody the spirit of several Federal laws and initiatives, including the Government Results and Performance Act of 1993, the Administration's Reinventing Government Initiative, and APHIS' Strategic Plan.

      In April 1996, APHIS first published the Strategic Direction for the Animal Care Program. This Strategic Plan also included the Horse Protection Program. In 1997, a separate strategic plan was developed for Horse Protection. The January 2000 Strategic Plan is solely reflective of the program supporting the Animal Welfare Act.

      The 1996 Strategic Plan was implemented from 1996 to 1999 with the involvement of teams of frontline employees. In June 1999, AC management convened a team of AC employees (Appendix A), representing all levels and regions of the program, to evaluate the Animal Care Program and suggest methods of improvement. The team was supported by APHIS' Policy and Program Development (PPD) and Legislative and Public Affairs (LPA) staffs. The team was asked to project Animal Care's future operations under a scenario of very limited resources, and another which forecast a modest increase in resources.

      II. Issues Facing Animal Care

      Many issues face AC and create the need for updating the strategic plan.

      A. Dealers and Exhibitors

      Pet Theft. A primary concern is the ongoing public perception that pet dogs and cats are stolen for use in research. The research community and USDA have made significant strides in protecting pets. The public should be informed of these measures and their effects in minimizing the potential of pet theft for use in research. A more recent concern is that pet dogs and cats are stolen for breeding purposes or fighting.

      Exercise for Dogs. The AWA requires a performance based program of exercise for dogs at licensed or registered facilities. Facilities usually fulfill this requirement by providing a larger primary enclosure. AC believes that socialization with humans and/or other dogs is also important for the well-being of the dog.

      Renewal of Licenses for Chronic Violators. Chronic violators are presently allowed to renew their licenses without impediment. AC needs the authority to deny license renewal of those facilities which are chronic violators.

      Education of Licensees. Some licensees, especially those who have never been regulated and those who are not involved in associations or other industry activities, need to be better educated about quality animal care, USDA's minimum requirements, and the Federal regulatory process.

      Animal Handling. There are several issues concerning the health and well-being of animals, and public safety:

      Identification. The lack of proper identification of animals limits the ability to track, improve accountability, and prevent dangerous situations.

      Emergency Disaster Preparedness for Animals. There is no comprehensive requirement addressing how regulated animals will be cared for in emergencies and life threatening situations, such as natural disasters.

      B. Research

      Rats, Mice, and Birds. USDA is considering regulating laboratory rats, laboratory mice, and birds, as authorized by the AWA. AC is concerned that regulation of these species, with existing resources and under the current inspection processes, may compromise existing regulatory activities.

      IACUC Oversight. As a result of the 1985 amendments to the AWA, research facilities are required to have an internal oversight body, the Institutional Animal Care and Use Committee (IACUC). AC is concerned about the effectiveness of some IACUCs' oversight of animal care and use, and the effectiveness of AC's regulatory authority over these committees. This includes IACUC oversight of adequate pain and/or distress relief, and the use of alternatives to procedures that may cause more than momentary pain or distress.

      Genetic Engineering. Technological advances, such as genetically altered or transgenic animals and xenotransplantation, will pose new challenges to AC for ensuring animal well-being.

      Nonhuman Primate Enrichment. Although there are facilities which provide good performance-based environmental enhancement, other research facilities, breeders, and exhibitors do not. Further clarification of the enrichment standards is needed to facilitate compliance by those facilities.

      Farm Animals. An extensive amount of research has been conducted on standards for farm animals used in regulated activities, but specific AWA regulations have not been developed.

      C. Animal Transportation

      Safe Air Transport. Incidents of escape, injury, and death of pets shipped by air have increased public awareness of the importance of safe animal transport. AC must continue to ensure safe transport and direct program resources effectively.

      Scientific Data. Safe transport depends on using valid scientific data on animal health in varied environmental conditions. Penalties collected for AWA violations should be directed toward gathering useful information to improve transportation standards.

      D. Resources

      During the 1900's, AC's appropriation has essentially remained static while the cost of conducting the program has increased. AC must continue to seek innovative ways to maximize its resources and remain effective.

      Availability of Inspection Results on the Internet. The previous E-FOIA posting of inspection results did not provide descriptions of specific violations, only counts of the noncompliant and corrected items. While seeking to comply with the provisions of E-FOIA, AC wants to ensure that publicly released information fairly portrays inspection results through full implementation of the new inspection data base.

      Adopting Standards From Other Sources. The process of creating policies and standards is time consuming. Some existing industry standards could be used effectively, while minimizing the time and expense of promulgating and periodically updating additional regulations.

      Confiscated Animals. In severe cases of animal abuse, confiscation is an option under the AWA. Sometimes, AC cannot take this action because it is difficult to find an appropriate facility capable of or willing to house the animals. The regulations limit the types of situations under which AC can confiscate animals.

      State and Local Regulation. A number of states and localities require a USDA license in order to own certain animals, even though a license would not otherwise be required under the Act. Licensing and inspection of these additional facilities creates an increased burden on AC's resources. This situation also fosters exhibition of dangerous animals by under-qualified persons.

      Continuing Education. AC's inspectors must continue to receive quality training, to remain up to date on animal care issues and new technologies. This is increasingly difficult with limited resources.

      Increase Public Awareness. Some members of the public do not fully understand the extent and limitations of AC's regulatory authority. This is often perceived by the public as an unwillingness to take action, instead of a lack of authority.

      III. Improvement Initiatives

      The basic tenets below, adopted in AC's 1996 Strategic Plan, are useful in organizing the approach to future program initiatives:

      Enhance statutory, regulatory, and procedural authorities.

      Encourage excellence in animal care.

      Maximize resources for enhanced program delivery and efficiency.

      Respond to external concerns and expectations through objective action.

      Empower, support, and develop employees.

      This section describes activities supporting these ongoing initiatives, as well as new strategies and objectives necessary to accomplish these goals. Each section includes a progress report on the initiatives outlined in the 1996 plan, listed here as Update of Ongoing Activities. Also included are some additional strategies developed by the 1999 Strategic Direction Team, listed as Strategies for Continued Improvement.

      A. Enhance Statutory, Regulatory and Procedural Authorities

      Update of Ongoing Activities

      Field Input. The Technical Advisory Group (TAG), composed of Supervisory Animal Care Specialists (SACS), a field ACI, and a Staff Officer from headquarters, currently reviews and processes suggestions for regulatory and policy improvements. The TAG, working with other AC teams, has produced a concise set of policies. The policies have helped:

      Forms Revision. AC now employs a narrative style inspection report. Compared to the previous format, this report is more user-friendly for licensees and registrants and takes less time for AC inspectors to complete.

      Quality Case Building. Inspectors routinely provide photographs with inspection reports submitted to Investigative and Enforcement Services (IES) for investigation. The Office of General Counsel (OGC) and IES have emphasized the importance of photographs and photographic technique to inspectors. AC provided inspectors with digital cameras in 1999. Inspectors are encouraged to request that an additional inspector or IES investigator accompany them when an investigation is anticipated.

      Innovative Case Prosecution. AC has continued to use innovative sanctions with great success. Monetary penalties have been directed toward research into such areas as the treatment of tuberculosis in elephants and safe transport for pets. Penalty funds have been allocated to the support of a sanctuary for elephants. AC routinely requires training and consultant reviews as part of stipulated penalties and consent decisions. License suspensions as part of stipulated penalties and consent decisions continue until the facility is in compliance and the monetary penalties are paid.

      Strategies for Continued Improvement

      Completion of Proposed Initiatives. To continue the progress that has been made toward enhancing AC's statutory, regulatory, and procedural authorities, the Strategic Direction Team recommends completion of the initiatives outlined in Appendix B. As of December 1999, some of these changes were in the clearance process and could be implemented in the near future.

      New Regulatory and/or Policy Developments.

      Transportation Standards. The development of new standards, or the incorporation of existing industry-specific transportation standards into AC regulations, would improve the quality of care animals receive during transport. This is particularly true for the animals listed in Subpart F. Specific standards would increase the uniformity of inspections and make it easier to prepare transportation violation cases. AC should also increase educational efforts with the transportation industry.

      Uniform Penalty System. AC should evaluate the penalties assessed over the last several years, to determine whether:

      Any changes in the penalty system which result from this assessment should be coordinated with APHIS' Investigative and Enforcement Services (IES), USDA's Office of General Counsel (OGC), and AC management to ensure appropriate implementation.

      Quality Case Building. A team of specialists from IES, OGC, and AC should be dedicated to enforcement of the AWA. This clearly identified group would be devoted to working on technically difficult, high profile, and critical cases. Specialization of investigative and legal personnel would increase the quality of enforcement actions. Concentrating resources on the problem would improve the timeliness of the actions.

      AC should continue to provide state-of-the-art photographic equipment and appropriate training. This will increase the effectiveness of inspectors' testimonies when administrative proceedings are required.

      Enforcement efforts could be enhanced by dedicating personnel in IES and OGC to Animal Welfare Act cases. Animal Care, with these other divisions of APHIS and USDA, should explore areas where specialization of investigative and legal personnel could increase the effectiveness of the AC enforcement system and inspection staff.

      Forms Revision. Inspection reports will be entered into a comprehensive data base which will maintain all relevant information about AC customers, including the narrative description of any noncompliant items. Plans are in place to revise and automate application, acquisition, inventory, and annual report forms for licensees and registrants. The automation of AC forms and reports should be considered a high priority.

      B. Encourage Excellence in Animal Care

      Update of Ongoing Activities

      Regulation of Research. AC has written and disseminated policies clarifying alternatives, painful procedures, multiple major operative procedures, Institutional Animal Care and Use Committee (IACUC) membership, and annual reports. An inspector's manual for inspection of research facilities is in preparation. It will be available to the research community and the public. In preparation for training in FY 2000, inspectors have completed a survey to identify training needs on IACUC issues. A survey on the effectiveness of performance standards for environment enhancement for non human primates was conducted. As a result of an intensive effort by a team of field inspectors, a proposed policy has been published in the Federal Register for comment.

      Industry Education. Teams have been established for inspector training and industry training. Agency representatives have participated in dealer, research, exhibitor and transportation meetings. Specific training of industry employees in animal care and handling has been required as part of several stipulated penalties and consent decisions. This has resulted in training of elephant and large cat exhibitors, as well as animal caretakers in research facilities.

      Incentive Systems. AC has designed a recognition system for exceptional facilities, the Partnership for Animal Care Excellence (PACE). Implementation as a joint program with a pet breeders' association is being explored.

      Strategies for Continued Improvement

      Industry Education. AC should take a leadership role in designing training courses for industry. AC needs to develop and conduct training specifically for operators of small businesses. Such training or educational conferences could be cosponsored with various industry groups. For example, AC could design an educational seminar for dog and cat dealers in the Midwest that could be cosponsored with industry groups.

      The prelicensing period represents an excellent educational opportunity. Application materials could be expanded and made industry specific. Pictures or program examples from superior facilities should be distributed with application materials. Website tutorials could be provided.

      Mentoring of applicants by other facilities should be explored as another educational avenue and an important step toward self-regulation.

      AC could establish an airline liaison position, to provide education to airline employees and coordinate cross-utilization of APHIS employees from Veterinary Services (VS) and Plant Protection and Quarantine (PPQ) at airports. This type of position could serve as a much needed career ladder for ACIs.

      Attending veterinarians are an untapped source of assistance. Teaching veterinarians at regulated facilities, veterinarians in private practice, and students in veterinary schools about the AWA regulations could lead to improvements in the quality of care in regulated facilities.

      Public Information. A central clearinghouse or information center should be established to respond to public complaints, answer questions, and develop training and public affairs materials. The clearinghouse would be responsible for ensuring that information regarding the Animal Care program is published in industry and scientific journals. This central clearinghouse concept offers a way to standardize information coming into the agency and going out to the public and could free inspectors and supervisory staff for inspection duties.

      Industry Self-Regulation. Self-regulation should be encouraged across all regulated industries. Building on the IACUC model, pet brokers could be encouraged to be responsible for the breeders from whom they purchase animals.

      AC should explore an expanded partnership with industry organizations such as the Association for Assessment and Accreditation of Laboratory Animal Care International (AAALAC) and the American Zoo and Aquarium Association (AZA). Validation of their inspection and certification programs would allow AC to leverage our resources through the work of these groups.

      IACUC's are generally successful in their oversight at research facilities. However, some IACUC's do not function adequately. AC needs to encourage effective program oversight and training by these IACUCs. A variety of options should be explored.

      Internal Review. AC recognizes the need to develop a system for a semi-independent review of its program. This review process should evaluate the effectiveness of AC activities. This review should at least include:

      A process should also be developed for self-assessment of AC activities, based in part on the findings of the semi-independent study. The routine use of these reviews of AC operations will allow management to evaluate the program and establish internal controls. These reviews can be used to establish the following:

      Incentive and/or Recognition System. AC should explore a simple recognition system to provide immediate positive reinforcement for extra efforts by regulated facilities.

      C. Maximize Resources for Enhanced Program Delivery and Efficiency

      Update of Ongoing Activities

      Risk Assessment. The Risk-Based Inspection System (RBIS) has been implemented across the country. Inspection resources are being directed to those facilities with the greatest risk of noncompliance. In addition, problem groups have been targeted for increased inspection. This has resulted in increased oversight and better compliance in these groups, which include random source class B dealers and traveling exhibitors.

      Teaming. Animal Care Inspectors work routinely with each other and IES investigators on 'animal incidents' and chronically noncompliant facilities. VS employees, with AC guidance, are doing limited transportation inspections.

      Enhanced Enforcement. A priority case list has been developed to focus resources on the most important AWA cases. Innovative sanctions have directed the penalties to where they will do the most good. Better quality cases and more interaction with IES and OGC have accelerated the enforcement process.

      Consolidation. As part of a Department-wide office collocation initiative, AC's Eastern Regional office has been relocated to Raleigh, NC. The consolidation of the Western and Central Regional offices is scheduled for November 2001. AC has effectively moved resources from headquarters to the field and reduced the number of staff officers.

      Funding Mechanisms. User fee authority to shift the burden of paying for AWA activities has not materialized. However, the AC Deputy Administrator and the AC Management Team have been actively pursuing revenue sources and reallocating existing funds. The budget outlook for AC has improved substantially. Continued efforts are critical to ensure sufficient funds.

      Strategies for Continued Improvement

      Risk Assessment. The initial implementation of RBIS has focused inspections on "at-risk" facilities. At this point, the system should be evaluated and further refined to review (and possibly reduce) the frequency with which certain groups and classes of licensees are inspected. The review should include consideration of the possibility for inspecting a sample of animals.

      To best utilize resources and manage an increasing workload, a study of alternatives to the present inspection system should be performed. The study should include options such as alternating years between facility inspection and program reviews at research institutions.

      A risk-benefit analysis of current procedures for licensing and inspecting pet stores should be conducted, to evaluate benefits relative to the time spent in this activity.

      Guidelines should be developed for certain specific situations, to allow inspectors to notify licensees and registrants that they are en route to perform an inspection at their facility. This would reduce time wasted on attempted inspections, without compromising the inspection process.

      Teaming and Partnerships. AC can leverage inspection resources by partnering with government agencies and individuals. Building relationships with other groups can lead to an opportunity to use information gathered by them, increasing the effectiveness of the program. AC should explore partnerships with:

      Enhanced Enforcement. AC should explore a coordinated nationwide effort to identify serious chronic violators and direct resources toward swift correction. A team approach could be used to inspect and develop cases at problem facilities. The approach could include full or complete record audits if necessary. These teams would need management support and adequate resources. This approach could result in uniformity of enforcement action, higher quality cases, a reduction in unproductive repeat inspections, and general support for collaborative action by AC inspectors.

      AC should evaluate the possibility of directing monetary penalties to a fund which would provide for animal welfare education and the housing of confiscated animals. The present system provides for the deposit of collected penalties into the U.S. Treasury; it is proposed that penalty monies be used to directly benefit the animals.

      AC should develop a set of standard operating procedures that AC inspectors could use to build cases and gather evidence.

      Innovative Staffing. The AC Management Team should continue to consider staffing options such as using experienced and qualified part-time local VMO's and ACI's, retirees, and relief inspectors. This would minimize travel time and maximize inspection time at facilities.

      D. Respond to External Concerns and Expectations through Objective Action

      Update on Ongoing Activities

      Public Meetings. AC continues to meet with the public to discuss animal welfare issues. Regular meetings with industry and animal welfare organizations provide information about AC. Large meetings are also held periodically to obtain input on various issues. These are announced in the Federal Register and open to all members of the public.

      Information Dissemination. Proposed regulation changes, such as those providing for the regulation of hunting, breeding and security dogs, are published in the Federal Register for public comment. Proposals and final regulation changes are immediately accessible from the AC home page (www.aphis.usda.gov/ac) and the APHIS page on rules and notices (www.aphis.usda.gov/ppd/rad/webrepor.html).

      Some proposed policy changes, such as the testing of elephants for tuberculosis and the providing of environmental enhancement for psychological well-being of nonhuman primates, were also published in the Federal Register for public comment. They were accessible on the home page and sent to affected parties. All policies are well formatted, numbered and easily accessible to the public and regulated community.

      Use of the APHIS World Wide Web site is increasing as regulations and policies, forms and contact information continue to be posted. The inspectors and staff have access to the site and have been trained to direct others to this valuable source of information.

      A position statement discouraging untrained people from keeping large, wild and/or exotic dangerous cats (e.g., lions and tigers) as pets has been published.

      A full-time Legislative and Public Affairs position has been fully funded by AC to improve information dissemination and concentrated outreach efforts, such as the Traveling With Your Pet campaign.

      An automated telephone information system, the Voice Response System (VRS), continues to be a resource for veterinarians, dog and cat owners, and airline personnel involved in the transportation of animals.

      Outreach. The full-time public affairs specialist provides a quarterly newsletter that is circulated to more than 2,000 subscribers from the public and regulated community. A second public affairs specialist works with the media to provide accurate information through scheduling and coordinating interviews, writing press releases, and handling individual requests for information. The AC Webpage is a source of current and archived information with links to other pertinent information. The outreach, media, and Webpage efforts have combined to make AC a leader in providing information to the regulated industries and the public.

      AC created and coordinates the Missing Pet Network (MPN), which is an Internet site that links more than 50 Websites that identify lost or found animals. The MPN covers the United States, Canada and European countries. This serves as a central place for the public to post notices about lost and found dogs, cats, and horses. MPN can be found on the AC Webpage.

      A survey has been developed to determine how animal interest groups view AC's progress. The survey should be disseminated in 2000.

      Strategies for Continued Improvement

      Information Dissemination. The Dealer Inspection Guide, as well as the Research and Exhibitor Inspection Guides which will be developed later, will be available to the public on request and accessible electronically.

      Continued expansion of the Website has great potential to benefit AC. The use of electronic requests for forms, on line applications, renewal and credit card payments, and annual reporting of animal usage directly into the data base should be instituted as soon as possible. AC should ensure that all licensees and registrants receive important news and information through other means as well.

      E. Empower, Support, and Develop Employees

      Update of Ongoing Activities

      Training. AC has an Internal (AC employees) and an External (regulated entities) Training Team. The teams are composed of field inspectors, supervisors, and APHIS training personnel. Surveys of training needs have been conducted annually. Training courses and other training opportunities have been planned accordingly. National and regional meetings have addressed conflict and stress management, customer service, and the importance of quality inspections. Dog dealer inspections, elephants, computer skills, and the Risk Based Inspection System have been the subjects of recent courses.

      The Dealer, Research and Exhibitor Inspection Guides will be educational resources for new inspectors and will increase uniformity among experienced inspectors.

      Employee Certification. Under the field specialty certification program, inspectors can be certified as specialists in specific areas. The program has its first four participants. Certifications in research animal pain and distress, elephants, great apes, and small animal nutrition are in progress. The research preceptorship program has had nine participants, and now includes course work in Midwest research institutions.

      Equipment. All AC inspectors and supervisors now have state-of-the-art laptop computers, which are used for reports, e-mail and other correspondence, and access to the Internet. The new comprehensive Licensing and Registration Information System (LARIS) data base has been developed and will soon be in full operation. The data base will allow greater access to information for all AC personnel. It will increase the type, amount and accuracy of data AC can collect and disseminate.

      Career Advancement. Several AC employees are graduates of previous APHIS leadership programs, and others are participants in the new leadership and development program.

      AC established an Inspector of the Year award in 1998. Two honorees have been publicly recognized for their inspection efforts. AC will continue this award program.

      Internal Communication. A series of strategic direction updates kept AC employees current during a period of major change. Now that strategic direction activities have slowed, the field receives periodic updates from the supervisors, Regional Directors, and the Deputy Administrator. Quarterly reports of the status of every outstanding enforcement case are sent to the field inspectors.

      Regional and national meetings also promote communications between headquarters and field personnel.

      Strategies for Continued Improvement

      Supervisory Support. Supervisory Animal Care Specialists play a key role in the effectiveness of the AC program, particularly in the success of strategic direction initiatives. Supervisors need to be a part of the decision making process. Their efforts to support innovative inspection methods and empower their field inspectors should be enhanced. These goals can be realized by providing a system for evaluation and improvement of supervisory skills, by relevant training, and by ensuring that their equipment and working environments are conducive to support of the program. AC should continue to review the roles of the supervisors and the supervisory structure, to insure that the needs of the changing organization are met.

      Training. The current training system identifies and provides training for the organization as a whole. A systematic method is needed to identify and meet individual training needs, perhaps on a local level.

      Future training priorities should include IACUC issues and environmental enhancement for the psychological well-being of nonhuman primates.

      Investigative and Enforcement Services investigators should be encouraged to receive advanced training in research, medical, and technical aspects of the Animal Care program. AC inspectors could benefit from training in investigative methods.

      Equipment and Personnel. AC priorities should include continued vehicle replacement to avoid having a large number of high mileage vehicles.

      AC should provide cell phones for inspectors.

      Employee grade levels should be increased to be commensurate with equivalent APHIS positions in other program areas.

      Funds should be allotted for awarding employees for high performance and specific acts of service.

      Career Advancement. AC should consider new advancement opportunities for employees, especially ACIs. These opportunities, such as career ladders, should be factored into staffing and organizational structure decisions. Possible positions referenced earlier in this document, such as transportation trainer, field specialist, or information center officer, could fulfill this need.

      Communication. Headquarters personnel should participate in field inspections and inspectors need to spend time at headquarters or in the regional offices. This cross-training will enable AC personnel to work better as a unit.

      Appendix A: 2000 Animal Care Strategic Direction Team

      The Strategic Direction for the Animal Care Program, January 2000, was developed over a period of several months in the summer and fall of 1999 by a team of APHIS employees designated by the Animal Care Management Team. They were:

      The team was supported by:

      The team was asked to take a comprehensive look at the current state of APHIS' Animal Care Program and the issues facing it, develop a positive and comprehensive road map for the next 3 to 5 years, and produce a final report. The team was to consider how AC would be structured and operate at various funding and staffing levels, including at least one static funding scenario and one slightly increased funding scenario. The team was to recommend the best ways to fulfill AC's mission. Details would later be developed by managers and project implementation teams.

      The team members held two meetings at APHIS Headquarters in Riverdale, MD, reviewed the 1996 strategic direction, and identified issues facing AC. Members discussed possible strategies for continued improvement, making decisions by consensus. Between meetings they consulted colleagues in regional offices and the field about concerns and ideas. Midway through the process, the Deputy Administrator was able to provide updated information that lowered the priority for development of alternative budget scenarios. After this change, it was agreed that the best way to organize the material was to address and update the tenets and direction provided by the 1996 Strategic Direction Plan. It was decided to present the report on resources and operations with a minimum of detail, because these areas are subject to constant change.

      Appendix B: Proposed Legislative and Regulatory Changes

      The following lists include suggested AWA amendments and proposed AWA regulation changes as of December 1999.

      Proposed Legislative Changes

      Proposed Regulatory Changes