agencies and be required to register or obtain permits from three or more agencies. This overlap presents a significant regulatory burden to individual investigators trying to navigate this complex network of regulatory authority. Establishing one federal entity that can be consulted would greatly reduce regulatory burden for shippers, whether they are individual investigators or large commercial operations. Such a working group also has the potential to centralize and reduce the number of redundant inspections and permits that must be issued for each shipment.
There is also substantial room for improving the comprehensibility of the various federal regulations. The committee was particularly concerned with areas of inconsistency and obscurity in the Animal Welfare Act (AWA) regulations, which are the federal regulations that establish standards for animal welfare that apply to most species of research animals during transportation. The AWA regulations are organized by groups of common species: 9 CFR 3 subpart A details standards for the transportation of dogs and cats, subpart B covers guinea pigs and hamsters, subpart C covers rabbits, subpart D covers nonhuman primates, etc. In this way, species with similar physiology and behavioral characteristics are regulated by the same standards. While differences between species account for the majority of differences in standards between species groupings, there are several cases of inconsistencies that have no apparent underlying scientific reason. For example, the regulations pertaining to dogs and cats state that the cargo area must be pressurized when flying above 8,000 ft (9 CFR 3.15(d)). There is no similar requirement for nonhuman primates, rabbits, guinea pigs, or hamsters. Another example involves acclimation of guinea pigs. For all species besides guinea pigs, there is a provision in the AWA regulations for transporting animals in temperature conditions that fall below the minimum allowed temperature if the animal has been acclimated to lower temperatures as certified by a USDA-accredited veterinarian (e.g., 9 CFR 3.13(e)). However, no such provision exists for guinea pigs, though there is literature suggesting that guinea pigs can be successfully cold-acclimated (Sobel et al., 1960, 1965; Vapaatalo et al., 1984).
There are also a number of inconsistencies in standards that apply to the same animal. For example, for nonhuman primates, the temperature in a terminal facility cannot fall below 45°F for more than four consecutive hours (9 CFR 3.91 (d)), but the temperature during handling (movement into or out of a terminal facility or conveyance) cannot fall below 45°F for more than 45 minutes (9 CFR 3.92(a)(3)). During air transport, the ambient temperature inside the plane must be maintained at a level that ensures the welfare of the nonhuman primate (9 CFR 3.88(d)); however, during surface transportation, the temperature must be maintained between 45°F and 85°F (9 CFR 3.88(e)).