Animal Welfare Act Inspection Data

The Animal Welfare Act (AWA)

The AWA, signed into law in the U.S. in 1966, is the only federal law that regulates the handling and care of animals involved in certain transportation, breeding, exhibition, and research contexts. The U.S. Department of Agriculture (USDA)’s Animal and Plant Health Inspection Service (APHIS)¹ enforces the AWA, with personnel from its Animal Care unit conducting inspections of facilities regulated under this law.

¹ U.S. Department of Agriculture’s Animal and Plant Health Inspection Service

The Dataset

The great folks at The Data Liberation Project obtain, extract, document, make accessible and usable government datasets for public use. Their dataset based on USDA APHIS inspection reports² piqued my curiosity. Not knowing much, at the onset of this journey, about the AWA or who, what or how APHIS regulates activity under this law, I decided to probe this dataset and use what I uncovered in the data to direct further learning on this topic.

² The Data Liberation Project’s APHIS Inspection Reports page and GitHub repository

Entities Regulated under AWA

First up, who is regulated under the AWA? What categories do these entities fall into?

Figure 1 shows operations involved in commercial animal transportation (trucking companies, airline carriers, etc.), commercial pet trade, breeding, exhibition (zoos, circuses, aquariums, film industry etc.) and research (teaching, testing, etc.) facilities that use animals as all being regulated under the AWA.

Figure 1: The entities actively licensed or registered with APHIS under AWA as of Jul 28, 2023. Data source: https://aphis-efile.force.com/PublicSearchTool/s/

Spontaneous Inspections: Inspected vs. Not

APHIS Animal Care personnel perform three major kinds of inspections:

1. Pre-licensing (or re-licensing or new site) inspections
2. Routine unannounced compliance inspections
3. Focused unannounced inspections in response to a complaint or tip from the public related to non-compliance

I was particularly interested in the latter two kinds of inspections as they involved spontaneous visits. Does every actively regulated entity get subjected to some form of spontaneous inspection?

Figure 2 shows a couple of categories, namely Class T - Carrier and Class H - Intermediate Handler, for which a majority of entities within the category don’t receive unannounced visits at all once registered.

Figure 2: The number of entities within each category that were spontaneously inspected at least once vs. never spontaneously inspected. Several different types of inspections were found in the data extracted from the reports. For this analysis, Routine, Focused and Attempted inspection types were all counted as a spontaneous inspection. (P)re-license, New Site and Unspecified inspections were not counted.

Spontaneous Inspections: Frequency

How many inspections, of the kind that involve unannounced visits, are conducted monthly, year over year, for each category?

Figure 3 gives a sense of where APHIS focuses its unannounced inspection efforts.

Figure 3: The number of inspections by month and year for each category of regulated entity. Several different types of inspections were found in the data extracted from the reports. For this analysis, Routine, Focused and Attempted inspection types were all counted as a spontaneous inspection. (P)re-license, New Site and Unspecified inspections were not counted.

Lack of Compliance

Non-compliance issues cited during inspections can be marked as Non-Critical, Critical or Direct. Direct non-compliance is an issue that is not only Critical , but is at the time of the inspection, having a serious or severe adverse effect on the health and well-being of the animal.³

³ Animal Care Inspection Guide Appendix C.

Figure 4 shows the number of issues split by the kind of non-compliance. Figure 5 visualizes which citation codes are commonly violated when a Direct or Critical non-compliance issue is discovered. Figure 6 lists information about all Critical and Direct non-compliance issues including links to individual inspection reports.

Figure 4: Number of issues by kind (Critical, Direct, Non-critical) of non-compliance

Figure 5: Proportion of Direct and Critical non-compliance issues by citation code. The text on any tile indicates the citation code, the area of the tile is proportional to the number of issues cited with that citation code.

Figure 6: Interactive table listing all inspection reports containing Critical and Direct non-compliance issues. The columns are sortable and can be filtered to narrow down on particular dates, codes, non-compliance kinds and entity categories

Species

Which species of animals, in practice, receive protection under this law?

At the end of every inspection report is a list of the species of animals inspected along with the number of individuals of each species. Figure 7 plots the number of unique inspection reports involving any given species against the total number of inspected individuals of that species (not necessarily unique individuals as repeat inspection visits to the same facility might result in re-inspection of an individual), split by regulated entity category. Species that are up and to the right of a plot, have more “coverage”, i.e. more individuals inspected and more inspections involving the species, than species lower and to the left of a plot.

Species

Total number of inspected individuals of species

Total number of unique inspection reports involving the species

Figure 7: The leftmost column has controls to filter the data on the right with. On the right, each regulated category has a separate plot corresponding to it. The vertical axes for each plot show the number of unique inspection reports involving a particular species, the horizontal axes show the number of inspected individuals (not necessarily unique as repeat inspections at a facility will result in re-inspection of some individuals) of a species. Hovering on a dot reveals the species and other information relevant to that point. The plots can be zoomed into.

Takeaways

Oversight Disparities

• Carriers vs. Others: There is less oversight over Carriers compared to Breeders, Dealers, Exhibitors, and non-federal Research facilities. See Section 3, Section 4 and Section 5.

• Historical Perspective⁴: The AWA, initially the ‘Laboratory Animal Welfare Act’, was established originally due to concerns about using stolen pets in labs. Presently, APHIS frequently inspects breeders, dealers, and non-federal research facilities, ensuring most are under scrutiny. The former two categories are likely considered inputs to the pipeline of animals supplied to research facilities.

• Exhibitors: A 1970 amendment added animals in places such as zoos and carnivals to the AWA purview. Current APHIS inspection data confirms rigorous oversight here.

• Carriers: Despite a 1976 amendment emphasizing protection of animals in transit, APHIS inspects carriers less frequently. With nearly 50% of all regulated entities being carriers, oversight here seems reduced, or perhaps monitored differently.

⁴ The Animal Welfare Act timeline

Standards and Inspections

• Generic Protocols: Many enforced standards are generalized and not tailored for specific species.

• Basic Protection Focus: The prevailing aim is to ensure basic survival and protection of animals (see Section 6 for the kinds of non-compliance issues most commonly cited). The goal doesn’t extend to the thriving or flourishing of animals, even in contexts such as exhibition where such a goal is not completely at odds with the purpose the animals are serving.

• Qualitative Assessments: Inspection reports mainly provide qualitative and subjective data. The absence of consistent metrics, lack of consistent or structured measurement of animal behavior, animals’ physiological data or environmental factors makes comparison and trend analysis challenging.

Significant Exclusions

• Definition Limitations: The AWA’s definition of “animal” omits birds, certain rats and mice used in research, and cold-blooded animals. Despite these animals dominating research, they aren’t protected at all under the AWA, even if they are listed in the inspection reports.

• Farmed Animals: These animals lack protection during their time on farms. Some, like livestock (but not poultry), receive protection during transportation under AWA.

• Miscellaneous Gaps: Livestock shows and rodeos are exempt from exhibitor regulations. Puppy mills and smaller scale commercial breeders are exempt from breeder regulations.