FASEB Submits Comments to USDA Regarding Environmental Enrichment Standards

By: Naomi Charalambakis
Thursday, March 23, 2023
On March 16, FASEB submitted comments to the United States Department of Agriculture (USDA) Animal and Plant Health Inspection Service (APHIS) in response to an Advance Notice of Proposed Rulemaking (ANPR) regarding environmental enrichment standards for USDA-regulated species. The purpose of the ANPR is to inform potential changes to the Animal Welfare Act, one of the U.S. laws that regulate the treatment of animals in research, teaching, and exhibition. Currently, the Animal Welfare Act requires institutions to have environmental enrichment plans for nonhuman primates and marine mammals, but the USDA is considering extending this requirement to all regulated species.

In its comments, FASEB cautioned against establishing a “one-size-fits-all” approach for new environmental enrichment standards. Specifically, FASEB emphasized that because of the vast differences between and among species, complex environments can frequently result in unintended consequences that jeopardize animal health. To safeguard human and animal safety, FASEB’s comments stressed the importance of ensuring new requirements are well documented and science-based, with clear evidence that interventions result in benefits to animal welfare. Additionally, FASEB urged USDA to ensure potential new requirements do not pose an administrative or financial burden for regulated entities, particularly small and under-resourced institutions. 

Given the breadth and complexity of environmental enrichment plans across institutions, FASEB's comments stressed the value of engaging with the stakeholder community before issuing proposed changes. Suggested strategies include public comment opportunities and listening sessions with researchers, veterinarians, farm managers, and animal care staff to fully appreciate current institutional practices and challenges.