Getting Better All the Time:
Applying USDA Guidance to Improve Yourself, Strengthen Your Team and Organization, and Better Serve Animals
By James F. Gesualdi
To keep ahead, each one of us, no matter what our task, must search for new and better methods for even that which we now do well must be done better tomorrow.
— James F. Bell
In the course of its administration and enforcement of the U.S. Animal Welfare Act (AWA), the U.S. Department of Agriculture (USDA) Animal and Plant Health Inspection Service (APHIS) Animal Care unit generates a lot of activity and produces an abundance of written and electronic information. Key activities and resources include licensing, facility inspections and outreach, enforcement actions, proposing and reviewing regulatory changes, and, increasingly, providing informal guidance to assist in complying with the AWA.
Before discussing the agency's most recent guidance and initiatives, please note that the agency's essential and other recommended publications can be accessed via its website at: https://www.aphis.usda.gov/aphis/ourfocus/animalwelfare/sa_publications/ct_publications_and_guidance_documents. Essential references include the following:
Most everything else on the website is recommended, and some items like Tech Notes are strongly recommended. Tech Notes provide agency guidance and suggestions as to how to address certain matters under the AWA. As the agency itself makes clear, its most recent Tech Notes, discussed below, are not regulatory requirements, but
"…are guidance documents that highlight ways for us to: encourage regulated entities to be even more proactive when identifying and correcting non-compliances under the Animal Welfare Act; and enhance the communication between our inspectors and attending veterinarians for the betterment of the animals' well-being."
Thankfully, for dedicated professionals like you, such a prominent acknowledgement that these are not "formal requirements" justifies even closer examination of these Tech Notes, including two recent and very significant ones.
Think of it like this: the federal agency having primary jurisdiction over animal welfare (relating to those activities and species covered under the AWA) has laid out recommended approaches and practices for complying with the law and helping animals. Great! Yes, even though not formally required, these establish an informal measure of AWA compliance and good practices. At the least, these Tech Notes should be understood, adopted, and followed, or used to develop alternative, effective good practices relating to the underlying requirements. Any of these approaches (as contrasted with ignoring agency guidance until something happens to trigger a belated review) makes you, your organization, and your animal-related efforts better. And, in the event you question agency guidance, respectfully presenting any concerns and alternative suggestions to the agency might further advance animal welfare nationally. This is how zoological, accrediting/certifying, and professional organizations build even better collaborative relationships, focused on constructive action to better serve animals.
In a USDA APHIS announcement released on December 15, 2017 (available at https://content.govdelivery.com/accounts/USDAAPHIS/bulletins/1cc8354), the agency provided information on two new Tech Notes in keeping with maintaining its goals as outlined in its USDA Animal Care Strategic Plan for 2016-2020. The Tech Notes are as follows:
Incentives for Identifying, Reporting, Correcting, and Preventing Noncompliance with the Animal Welfare Act, December 2017
". . . describes a new incentive program that recognizes licensees/registrants who routinely (self) monitor their activities and take appropriate and timely action to address noncompliant items."
(Available at https://www.aphis.usda.gov/publications/animal_welfare/2017/ac-tech-note-incentives-animal-welfare-act-compliance.pdf.) This encourages maintaining compliance, timely identification of potential non-compliances, immediate corrective action (including measures to prevent reoccurrence), and prompt self-reporting. The Tech Note indicates self-reporting should be within five days, and should include information specified in the document. Meeting the criteria set forth in the Tech Note may allow for a matter, including a certain non-compliance, to be addressed and reviewed without being written up in a formal inspection report. The portions of Excellence Beyond Compliance addressing organizational framework, inspection preparation and follow-up, and serious incidents provide useful insights on good practices to make the most of the opportunities afforded via this groundbreaking Tech Note.
Daily Observation, December 2017
". . . provides helpful information so licensees/registrants can better fulfill the regulation requiring them to assess the health and well-being of their animals every day."
(Available at https://www.aphis.usda.gov/publications/animal_welfare/2017/ac-tech-note-daily-observation.pdf.) The agency suggests means for consistently and effectively observing and assessing animals including their physical attributes, behavior and environment. See also, Excellence Beyond Compliance, "Observation and monitoring of animals, and communications regarding veterinary treatment."
In addition to the above Tech Notes and others available for review on the agency website, the agency has been prolific in launching other new initiatives. One is exploration of a potential revision regarding an often criticized license renewal process, where licenses are all but automatically renewed, even when there are recent open serious non-compliances. The agency's Federal Register notice is located here https://www.gpo.gov/fdsys/pkg/FR-2017-08-24/pdf/2017-17967.pdf and comments can be reviewed here: https://www.regulations.gov/docketBrowser?rpp=25&so=DESC&sb=commentDueDate&po=0&dct=PS&D=APHIS-2017-0062.
Another effort is an evaluation of incorporating professional association accreditation and certification into the determination of inspection frequency, an idea with interesting potential. To those weighing in on the upcoming review process, here's a suggestion. In advocating for such use of these third-party reviews, find ways to build upon those reviews so that exceeding AWA compliance and ongoing enhancements in animal welfare are the highest priorities, and there are means in place to continuously improve animal welfare.
Finally, the agency's 2018 activities and accomplishments have been summarized in a stakeholder announcement, report and poster available at https://content.govdelivery.com/accounts/USDAAPHIS/bulletins/1cf1c91, https://www.aphis.usda.gov/publications/animal_welfare/report-2017-accomplishments.pdf, and https://www.aphis.usda.gov/publications/animal_welfare/pos-2017-accomplishments.pdf, respectively.
Being aware of these underappreciated Animal Care guidance documents—and better understanding them and potential practical applications, and other agency efforts—opens up ever more ways for us to grow to be the best professionals and community of caregivers possible. For us, and the animals we love, it is well worth the effort.
You had better live your best and act your best and think your best today; for today is the sure preparation for tomorrow and all the other tomorrows that follow.
The best preparation for tomorrow is doing your best today.
—H. Jackson Brown, Jr.
Join us on Thursday, January 25, 2018, 3 p.m. EST, for a very special Ask Animal Care. Joining us from USDA, APHIS will be Bernadette Juarez, deputy administrator; Elizabeth Goldentyer, DVM, associate deputy administrator of Animal Care, and Robert M. Gibbens, DVM, director of Animal Welfare Operations. Register and submit questions
For more information on the AWA please see my article, Animal Welfare Act: Good Practices to Advance Animal Interests and Well-Being, published in the Fall 2017 edition of the American Bar Association, Tort Trial and Insurance Practice, Animal Law Committee Newsletter, which is available upon request to email@example.com.
For more information on Excellence Beyond Compliance®, visit excellencebeyondcompliance.com.
©2018 James F. Gesualdi, P.C. The opinions expressed herein are solely those of the author. This is not, nor should it be construed as, legal advice.
Something Fishy Is Going On
By Dr. Rob Jones, "The Aquarium Vet"
Welcome to 2018. Where do the years go? I still vividly remember the lead-up to the new millennium in 2000, and the "millennium bug" that was going to cause world collapse, with planes falling out of the sky and financial services collapsing. None of that occurred—and here we are, 18 years later.
Fish are the most amazing group of vertebrates on the planet. There are over 30,000 species, which is more than all the other vertebrate species combined. They live in all aquatic ecosystems on the planet. How do they survive in this aquatic environment? Through a process called osmoregulation.
Osmoregulation is the active regulation of the osmotic pressure of an organism's body fluids, to maintain the homeostasis of that organism's body water. Remember that homeostasis refers to a constant balance state or equilibrium of the body. Osmotic pressure is the pressure that must be applied to a solution to prevent the inward flow of water across a semi-permeable membrane—in this case, mainly the skin, gills, and intestinal tract.
Water can contain a wide variety of salts (the ions). The amount of salts (the salinity) can range from almost zero in a freshwater forest stream; to seawater, which contains salts at 35 parts per thousand (ppt); to hypersaline desert ponds, which can be greater than 100 ppt. Fish have thus developed a whole series of osmoregulatory mechanisms for coping with these wide-ranging salinities and still maintain homeostasis. The osmotic concentration of fish blood is intermediate between that of fresh water (0 ppt) and seawater (35 ppt). It is almost the same as humans, and ranges between 8 and 10 ppt.
One simple example of how osmoregulation can affect us is when you have a prolonged bath or swim in fresh water and you get wrinkles on your fingers. This occurs primarily because your skin absorbs water (secondary blood vessel changes can also occur).
Osmoregulation is a very energy-intensive process and accounts for a large percentage of the energy required by fishes. Ions are the critical part of osmoregulation. There are two major groups of ions, which are handled differently by the body:
- Monovalent (only one charge, which can be either positive or negative)
includes Sodium (Na+), Potassium (K+), Chloride (Cl-), and Bicarbonate (HCO3-)
- Divalent (two charges, which can be either positive or negative)
includes Magnesium (Mg2+), Calcium (Ca2+), Sulphate (SO42-), and Carbonate (CO32-).
There are three organs of the fish body (gills, intestinal tract, and kidneys) that are actively involved in maintaining osmoregulation, and that have different roles in freshwater versus seawater fish. In the next newsletter, we will look at the specifics for freshwater fish.
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For more information about the SDZGA discount, or anything about the e-quarist™ course, including next month's free webinar, please contact firstname.lastname@example.org.
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