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OC submits comments on field study guidance

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The Ornithological Council submitted comments to the Animal Care program within USDA’s Animal Plant Health Inspection Service regarding guidance the program released last month, clarifying the definition of “field study “within the context of the Animal Welfare Act. 

The draft policy aims to assist research institutions in determining whether an activity involving free-living wild animals in their natural habitat meets the regulatory definition of “field study.” The proposed policy describes criteria that research facilities could use to identify activities that are invasive, harmful, or that materially alter animal behavior, and provides examples of activities that are and are not field studies.

The comments submitted by the Ornithological Council note that, without clear guidance on what is or is not a field study, the application of the term - and thus whether or not the Animal Welfare Act applies to research - has been inconsistent in the past. It notes that the examples provided in the draft policy are helpful, but urges APHIS to go further and provide either definitions or examples of key terms within the definition of “field study.”  The OC's comments are attached below. 

Read more about the draft policy here

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final OC comments on field study policy Oct. 2020.pdf

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