There are also instances in the Animal Welfare Regulations where there are inconsistencies in reporting and documentation. For example, the certification that must accompany dogs, cats, and nonhuman primates must include the name, address, and telephone number of the consignee (9 CFR 3.13(b) and 9 CFR 3.86(b)); however, this information does not have to be included in the certification that must accompany rabbits, guinea pigs, or hamsters. While inconsistencies in reporting and documentation are unlikely to affect the welfare of the animal directly, they make compliance with AWA regulations onerous, thus diminishing their effectiveness.
Though the committee had greater concerns about the AWA regulations because they directly impact the welfare of the animals, the committee found that all of the federal regulatory language lacked clarity. This makes it difficult to determine which federal agencies would oversee a particular transportation situation. In particular, it is exceedingly difficult to determine which federal regulations apply to the transportation of animals or animal products that contain a known or suspected zoonotic/ infectious agent, whether naturally occurring or experimentally induced (see Table 2-1). Federal agencies should work to clarify these issues, either through the development of an interagency working group or the issuance of guidance documents by the individual agencies.
Recommendation 5: Shipments of research animals between institutions should be coordinated between responsible individuals at both the sending and receiving institutions.
In the committee’s judgment, instances of mortality, morbidity, and adverse effects on animal health occur most frequently when individual investigators unfamiliar with the vagaries of the research animal transportation system ship animals to investigators at other institutions. Such problems can be avoided if each institution designates a single individual responsible for ensuring the safe shipment and receipt of research animals. This designated individual would ensure that communication between institutions is effective at all stages of the transport process; that all documentation including health certifications required by the receiving institution and all federal, state, and local permits are in order; and that animals are placed in shipping containers according to the appropriate standard. This designated individual would further ensure that USDA-certified carriers are utilized and that, upon receipt, the consignee is notified and places the animals in the appropriate level of biocontainment/quarantine before introduction into the laboratory colony. Though institutional animal care and use committees are not required to directly review each instance of animal transport, transport activities should be reviewed during the semiannual program evaluation to ensure that appropriate procedures are being followed (Silverman et al., 2000).