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Follow-Up to Animal and Plant Health Inspection Service’s Controls Over Licensing of Animal Exhibitors

OIG evaluated APHIS’ controls over the licensing of exhibitors of dangerous animals and the agency’s efforts to safeguard both the animals and members of the public who visit exhibitor facilities.

Audit Report: 33601-0003-23
Published: 03/12/2021
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Fast Facts

Under the Animal Welfare Act (AWA), the Animal and Plant Health Inspection Service (APHIS) regulates the use of certain warm-blooded animals in research, exhibition, and commerce in order to ensure their humane treatment. As part of its mission, APHIS Animal Care is charged with providing leadership in: (1) determining standards of humane care and treatment of animals; (2) implementing those standards; and (3) ensuring compliance with those standards through inspection, education, and cooperative efforts. All facilities that exhibit animals regulated under the AWA must be licensed with APHIS and be inspected on a periodic basis. As of December 2019, there were 2,245 Class “C” (Exhibitor) licensees nationwide.

APHIS Animal Care is headquartered in Riverdale, Maryland, with an operational office located in Fort Collins, Colorado. To ensure compliance with the AWA, APHIS inspectors must inspect all licensed facilities. The inspectors are located throughout the United States and conduct both announced pre-license inspections and unannounced routine and/or focused inspections on a periodic basis. As of December 11, 2019, there were 3 assistant directors that oversee the 14 supervisory animal care specialists (SACS); the SACS supervise 66 veterinary medical officers (VMO) and 43 animal care inspectors (ACI). During fiscal year (FY) 2019, APHIS inspectors performed over 2,800 inspections of exhibitors in their assigned geographic areas.

Animal exhibitors are public or private entities that exhibit animals to the public. Examples of exhibitors include individuals, public zoos, roadside zoos, circus/traveling exhibitors, and State parks. APHIS requires licensed exhibitors to provide their animals with adequate care and treatment in the areas of housing, handling, transportation, sanitation, nutrition, veterinary care, and protection from extreme weather and temperatures. Exhibitors must maintain, on their premises, accurate records of the animals that come into their possession and of the veterinary care the animals receive. Exhibitors must minimize possible harmful risks to animals and the public during public exhibition. Specifically, any animal must be handled to minimize the risk of harm to the animal and to the public, with sufficient distance and/or barriers between the animal and the general viewing public to assure the safety of animals and the public.

When APHIS inspectors identify items that are not in compliance with Federal standards, APHIS holds those facilities responsible for properly addressing and correcting those items within a specified timeframe. APHIS inspectors record the results of their inspections in the online Animal Care Information System (ACIS). To determine the timing of inspections, APHIS developed a Risk Based Inspection System (RBIS) to ensure that resources are effectively targeted and that entities with a “high risk” for noncompliant items (NCI) are inspected more frequently. APHIS uses factors, such as the number and severity of NCIs recorded in ACIS and potential for human injury through direct contact with dangerous animals, to determine inspection frequency for each exhibitor. The AWA authorizes the Secretary of Agriculture to suspend or revoke an exhibitor’s license for any violations of the AWA or the agency’s regulations and standards.

Prior Audit

In 2010, we evaluated APHIS’ controls over the licensing of exhibitors of exotic animals and the agency’s efforts to safeguard both the animals and members of the public who visit exhibitor facilities. The audit found that APHIS inspectors did not report safety conditions because the inspectors were challenged by APHIS’ broadly worded guidance while evaluating compliance at the facilities. We noted several instances in which APHIS inspectors either did not identify safety-related deficiencies during inspections, or did not document the conditions and require corrective actions due to the lack of periodic onsite supervision. We recommended that APHIS issue clear regulations and guidance that define what constitutes a sufficient public barrier and require exhibitors to report all escapes and attacks involving dangerous animals to APHIS’ ACIs. APHIS agreed to develop a work plan for a change in regulation and issue revised guidance. The audit also found that APHIS renewed United States Department of Agriculture (USDA) exhibitor licenses to individuals who could not provide evidence that they actually exhibited their animals. Additionally, APHIS inspectors were unable to timely locate traveling exhibitors (for example, circuses) to conduct inspections. APHIS agreed with the findings and achieved final action on all recommendations. Since the previous report was issued, APHIS has increased the use of its subject matter experts and SACS’ oversight of the APHIS inspectors through use of onsite supervision during inspections. Additionally, APHIS issued a new regulation that removed the license renewal process for exhibitors; specifically, licensees must reapply for their license every 3 years, instead of automatically being renewed upon payment of fees.


To evaluate APHIS’ controls over the licensing of exhibitors of dangerous animals, and to evaluate the agency’s efforts to safeguard both the animals and members of the public who visit exhibitor facilities. As part of this audit, we followed up on the recommendations from our previous audit, issued June 2010, with emphasis on the recommendations relating to public safety.

Our audit did not identify any deficiencies in the licensing of animal exhibitors. We evaluated APHIS’ final actions for all seven recommendations from the previous audit. (See Exhibit A). For Recommendations 2, 3, 4, and 7, the final actions taken by APHIS corrected the issue previously identified. For Recommendations 5 and 6, APHIS initially did not take action beyond obtaining an Office of the General Counsel (OGC) opinion. However, in May 2020, APHIS issued new regulations that addressed the Office of Inspector General’s (OIG) previously noted concerns related to Recommendations 5 and 6. Recommendation 1 is addressed in Finding 1 of this audit.