tative sampling of animals. For each dealer, tracebacks are performed on some animals at the facility at each inspection and on all animals present at the facility annually during one of the quarterly inspections. It must be made clear that due to the turnover of animals at a dealer facility, not all animals are traced back, only those on the premises at the time the inspection is conducted. In addition, during each quarter, approximately 25% of Class B dealers are now being subjected to 100% tracebacks of all acquisitions since the previous inspection and over the course of one year all Class B dealers will have undergone the process of 100% tracebacks. USDA inspectors are instructed to consider a traceback successful and complete when the origin of the animal has been traced to a legal source.

The USDA has expressed confidence that its increased scrutiny of Class B dealers is sufficient to address concerns about the Class B system and to keep pets out of the system. In 1998, Terry Medley, while serving as administrator of APHIS, stated in a letter to the House Committee on Agriculture, that the USDA was able to trace back original owners for more than 90% of the dogs brokered by Class B dealers (HSUS 2007; CBRA 2009), and Dr. DeHaven stated in testimony before this NRC Committee that in 2000 and 2001 the USDA was able to trace back original ownership for 95% of such dogs. This was well before the 2008 implementation of the new USDA SOP, Conducting Tracebacks from Random Source B Dealers, so it is likely that the current traceback figure is higher. But while such a success rate is admirable, it nonetheless suggests that the origins of 5-10% of animals in the Class B system are uncertain. Indeed, there remain loopholes in the system. For example, origination information is considered adequate if the sale of an animal is traced back to an auction. Thus, although there is no evidence that auction houses are currently used to sell animals to research institutions or Class B dealers, auction sales could serve as a mechanism to legitimize the sale of illegally acquired animals.

There is little evidence to prove that pets are stolen for research (HBO 2006) but the USDA could not offer assurances that pet theft does not occur, and agreed that such a crime is exceedingly difficult to prove, almost requiring an eyewitness. There are, however, descriptions of thefts provided by informants in prison (personal communication, Robert Willems, USDA, to Committee, January 2009) and documented accounts of lost pets that have ended up in research institutions through Class B dealers. For example, in June 2005, the University of Minnesota received from a Class B dealer a dog that was subsequently identified as a missing pet named Echo through microchip scanning by a veterinarian at the institution. Apparently Echo made his way to the university via a USDA-licensed Class B dealer from Michigan, who in turn reported buying Echo from another Class B dealer in Missouri (Fayetteville Free Weekly 2005).

The Committee requested FOIA access to USDA inspection reports over



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