	Background

For decades, animal dealers have been providing dogs and cats to  scientific researchers. These data  showed that the total number of dogs and cats sold for that period by  random source Class B dealers to research facilities was 3,139 animals  (2,863 dogs and 276 cats), which was equivalent to about 3 percent of the  total dogs and cats used in research in fiscal year 2008. APHIS Inspections Have Found Numerous Dealer Violations, but APHIS Has Not Completed All Tracebacks or Fully Analyzed Traceback Data

APHIS inspection reports documented one or more violations by seven of  the nine random source Class B dealers from fiscal years 2007 through  2009. Additionally, about 29 percent of tracebacks APHIS conducted  during this period were either unsuccessful or had not been completed as  of June 2010, as directed by agency guidance. During Fiscal Years 2007 to 2009, About One-Third of Inspection Reports Reviewed Cited Violations, and Seven of the Nine Dealers Had One or More Violations

Our review of all APHIS inspection reports from fiscal years 2007 through  2009 indicates that the agency has generally inspected, or attempted to  inspect, each of the random source Class B dealers at least four times a  year, as called for in APHIS guidance, and has documented numerous  violations among the dealers. According to APHIS guidance, when  conducting an inspection, inspectors are to examine the condition and  cleanliness of the dealer facility and the condition of the dogs and cats  present, among other things. Inspectors also are to review dealer records  pertaining to the acquisition and disposition of animals. As of July 2010, several of these dealers  were under further investigation by APHIS in light of repeated violations  and could be subject to fines or even license revocation in the future,  depending on the severity or history of violations. Some APHIS Tracebacks for Verification Were Unsuccessful or Incomplete in Fiscal Year 2009, and APHIS Has Not Fully Used Its Traceback Data

APHIS has performed tracebacks to verify the records of random source  Class B dealers since fiscal year 1993, but it only recently started to  compile traceback information using electronic spreadsheet logs. We found that APHIS attempted a total of 326 tracebacks in fiscal year  2009. As of June 2010, the data in APHIS’s traceback logs showed that  APHIS was able to successfully trace a dog or cat back to a legitimate  source in 231 of the 326 traceback cases, or about 71 percent of the time. Because APHIS does not analyze the data in its traceback logs, it cannot  systematically detect problems with its tracebacks. APHIS Does Not Collect Data on the Cost of Its Oversight of Specific Classes of Dealers, or Others It Inspects, Including Random Source Class B Dealers

According to APHIS officials, the agency does not collect cost information  for its oversight of the specific classes of dealers and exhibitors, or others  it inspects, including random source Class B dealers. Furthermore, APHIS  officials also told us the agency does not currently have a mechanism in  place to determine these costs. For example, APHIS inspectors do not  currently record their time by specific oversight activity or class of dealer. Without such data, APHIS is not employing  one of the standards of federal internal control. Recommendations for Executive Action

To improve APHIS’s oversight of random source Class B dealers who  purchase dogs and cats for research, we recommend that the Secretary of  Agriculture direct the Administrator of APHIS to take the following two  actions:  Improve the agency’s analysis and use of the traceback information it  collects, such as whether the same sellers or inspectors were consistently  involved in late or incomplete tracebacks, and ensure it is taking all available  steps to verify random source Class B dealers are obtaining dogs and cats  from legitimate sources, including making certain that tracebacks are  completed in a timely manner and conducted according to APHIS guidance. Develop a methodology to collect and track the oversight costs associated  with the specific classes of dealers, and others the agency inspects, including  random source Class B dealers, in order to identify potential problems  requiring management attention and develop a business case for changing  this oversight, if appropriate, to more efficiently use available resources. Appendix I: Objectives, Scope, and Methodology

Our objectives were to determine (1) the number of Class B dealers that  sell random source dogs and cats for research; (2) the extent to which the  U.S. Department of Agriculture’s (USDA) Animal and Plant Health  Inspection Service (APHIS) conducts inspections of these dealers and  verifies the accuracy of their records; and (3) the costs associated with  APHIS’s oversight of these dealers compared with its costs for oversight of  other types of dealers.
Why GAO Did This Study

For decades, the public has been concerned that lost or stolen dogs and cats could be used in research. The U.S. Department of Agriculture's (USDA) Animal and Plant Health Inspection Service (APHIS) is responsible for the licensing and oversight of dealers who provide animals for research. Random source Class B dealers--who generally obtain dogs and cats for research from individuals, pounds, and other dealers--have been the focus of this concern. GAO was asked to determine (1) the number of random source Class B dealers, (2) the extent to which APHIS conducts inspections of these dealers and verifies their records, and (3) the costs associated with APHIS's oversight of these dealers compared to other types of dealers. GAO reviewed the Animal Welfare Act (AWA); APHIS regulations and guidance; inspection reports; agency data, such as "traceback" data used to verify dogs and cats are not lost or stolen; and interviewed and reviewed documents from agency officials and other stakeholders.

What GAO Found

As of July 2010, nine Class B dealers were licensed by APHIS to sell random source dogs and cats for research. This number has not changed significantly since fiscal year 2005 but declined from over 100 dealers in the early 1990s. Random source dealers sold 3,139 animals to research facilities from November 2007 to November 2008--equivalent to about 3 percent of the dogs and cats used in research in fiscal year 2008. APHIS inspections have found numerous random source Class B dealer violations, such as the condition of animal housing and inadequate veterinary care, but APHIS has not completed all of its fiscal year 2009 tracebacks related to these dealers or analyzed traceback verification data to detect problems with the process. In reviewing all inspection reports for fiscal years 2007 through 2009, GAO found APHIS generally inspected, or attempted to inspect, each of these dealers at least four times a year, as directed. APHIS guidance directs inspectors to examine the condition of a dealer facility, examine the condition of the dogs and cats present, and review dealer records. Overall, 54 of the 156 inspection reports cited at least one dealer violation, and seven of the nine dealers had one or more violations. As of July 2010, several dealers were under further APHIS investigation due to repeated violations. To verify dealer records and help ensure dealers are not obtaining lost or stolen animals, APHIS attempted a total of 326 tracebacks in fiscal year 2009. Though APHIS has conducted tracebacks since fiscal year 1993, it did not compile traceback data until fiscal year 2009. As of June 2010, data showed APHIS successfully traced a dog or cat back to a legitimate source about 71 percent of the time. About 29 percent of tracebacks APHIS conducted during this period were either unsuccessful or had not been completed as of June 2010, as directed by agency guidance. Because APHIS does not analyze traceback data, it cannot systematically detect problems with tracebacks and take all available steps to ensure random source dealers obtain dogs and cats from legitimate sources. For example, without analyzing data, APHIS cannot know whether the same sellers or inspectors were consistently involved in late or incomplete tracebacks. According to APHIS officials, the agency does not collect cost information specific to its oversight of random source Class B dealers, or to any other class of dealer it inspects. Officials also said the agency does not currently have a mechanism to determine these costs. Federal internal control standards call for agencies to obtain such information for program oversight. For example, APHIS inspectors do not record their time by specific oversight activity or class of dealer. Without a methodology to collect and track costs associated with the oversight of these dealers, and others APHIS inspects, APHIS management cannot identify trends or deficiencies requiring its attention. Furthermore, management cannot develop a business case to change its oversight program, if needed, to more effectively and efficiently use available resources.

What GAO Recommends

GAO recommends that USDA (1) improve its analysis and use of the traceback information it collects for random source Class B dealers and (2) develop a methodology to collect and track the oversight costs of each class of dealer and others APHIS inspects. USDA agreed with GAO's recommendations and noted specific actions it will take to implement them.