The Council on Governmental Relations (COGR), representing over 200 research universities and affiliated institutions, submitted comments in response to the USDA Animal and Plant Health Inspection Service's (APHIS) advance notice of proposed rulemaking concerning wild and exotic animal handling, personnel training, and, notably, environmental enrichment standards for species covered under the Animal Welfare Act (AWA). COGR's remarks are focused on the environmental enrichment component, emphasizing the need for standards that are firmly rooted in scientific evidence, permit Institutional Animal Care and Use Committees (IACUCs) necessary flexibility to accommodate specific research protocols and animal welfare needs, and prioritize performance-based approaches over prescriptive engineering standards. The organization also highlights that enrichment interventions, while beneficial, can carry risks such as increased aggression, and cautions against automatically classifying such incidents as non-compliance.
COGR underscores the importance of data-driven, species- or genus-specific standards and urges USDA APHIS to consider both the quality and applicability of data when developing requirements. The comments call for flexibility in written enrichment plans, the application of performance standards tailored to diverse research environments, and attention to the practical and financial burdens these regulations may impose on research institutions, including costs for training, personnel, materials, and facility modifications. COGR recommends phased implementation of new standards and reasonable compliance timelines to help institutions adapt. The letter concludes by affirming the research community’s commitment to animal welfare and collaboration with USDA APHIS, expressing hope for ongoing dialogue to develop effective and practicable enrichment regulations.
