USDA Reportable Wildlife Field Studies
Guidance from USDA
The USDA Animal Welfare Act (AWA) states that field studies are exempt from the USDA requirement for IACUC review (section 2.31.d.1). It defines a field study as “a study conducted on free-living wild animals in their natural habitat. However, this term excludes any study involving an invasive procedure, harms, or materially alters an animal's behavior under study” (section 1.1).
These terms—"invasive," "harm," and "materially alter"—are not explicitly defined in the AWA itself, and in the past, the USDA allowed individual IACUCs to interpret and define these terms to determine whether a study qualifies as a USDA field study and is thus exempt from reporting. Although the AWA definition of a Field Study has not been updated to define the terms invasive, harm or materially altered, the USDA has now issued guidance on their interpretation of these terms. This updated guidance provides the 老虎机攻略 IACUC with a clear rationale for deciding whether a specific field study meets the USDA's criteria for exemption.
Additionally, the USDA, APHIS Animal Care Inspection Guide states that “animals euthanized, killed, or trapped, and collected, such as for study or museum samples, from their natural habitat via humane euthanasia” are not to be included in the USDA annual report. The AWA defines euthanasia as the “humane destruction of an animal accomplished by a method that produces rapid unconsciousness and subsequent death without evidence of pain or distress, or a method that utilizes anesthesia produced by an agent that causes painless loss of consciousness and subsequent death.”
Both chemical agents and commercially available kill traps are considered euthanasia, and, therefore, the killing of animals in the field by these methods does not exempt a study from being considered a “field study” for USDA purposes. Moreover, a rare accidental death during the use of live traps also does not disqualify a study from being classified as a field study. These nuances allow IACUCs to carefully evaluate and categorize field research in compliance with USDA guidelines.
USDA Definitions for Wildlife Field Studies Not Exempt from USDA Reporting
Invasive Procedures | Studies with major operative procedures:
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Harm |
Procedures in which animals may experience:
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Materially altered behavior |
Activities for research purposes that:
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Determination of whether proposed fieldwork qualifies as a USDA Field Study is made on a case-by-case basis by the IACUC based on the above definitions. However, below are examples of procedures that would make the proposed work suitable for classification as a USDA field study.
Field Study (exempt from USDA reporting) may include the following procedure
- Live-trapping animals in traps that are designed not to injure the animal and allow for some free movement within the trap
- Short-term handling of animals at the site of capture or a nearby field processing location
- Collection of external morphometric data
- Marking the external surface of the animal via hair clipping or visible marking techniques (e.g., Sharpie pen, picric acid on fur or feathers)
- Swabbing of the mouth, nostrils, or rectum
- Injection of sterile liquids or materials (e.g., transponder tags) that are not expected to materially alter an animal’s activity or behavior
- Ear punching or clipping in rodents
- Blood collection through a needle, hematocrit tube, or by way of a skin nick
- Attaching external bands, tags, or transponders to limbs, neck, feathers, or ears
- Sedation or anesthesia is used to immobilize an animal rather than to provide analgesia
- Euthanasia by inhalation, chemical injection, or commercially available kill trap