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USDA Asleep at the Wheel on Oversight of Commercial Dog Breeders

Are they even capable of enforcing the Animal Welfare Act? (AWA)

Since 1966, the USDA has been charged with overseeing commercial dog breeders. Under federal law, the Animal Welfare Act (AWA) is the only law that governs the humane treatment of animals bred for purposes of sale. Those who fall under the scope of the AWA must be licensed by the U.S. Department of Agriculture (USDA) through a branch called APHIS - Animal Plant Health Inspection Service. The USDA/APHIS creates minimum standards of care, licenses certain breeders, inspects their facilities, and enforces violations of the AWA.

Yet, for more than 15 years, multiple watchdog groups (#HSUS, #ASPCA, #CAPS, #moanimalalliance, and #BailingOutBenji, to name a few) have documented violations and inhumane conditions at scores of commercial dog breeding facilities. Many were repeat offenders who received no consequences thanks to lax reporting by the USDA.

Even the government’s own OIG (Office of Inspector General), as far back as 2011, released a scathing report detailing failure on the part of the USDA's APHIS to properly enforce AWA standards for commercial and internet dog sellers.


This post focuses on one specific program used by APHIS that makes a mockery of AWA implementation at puppy mills. It’s all almost unbelievable, except it’s true. It’s called “teachable moments.”

From 2016-2022 APHIS inspectors stopped issuing violations of the AWA by puppy mill breeders. Inspectors used their discretion to leave “minor” violations off their inspection reports. This was supposed to “educate” the puppy mills, research labs, or other USDA licensees through collaboration. It all amounted to barely a slap on the wrist while dogs suffered a multitude of abuse.

So, during inspections, non-compliant items were treated as "teachable moments" and not included on inspection reports issued to the facility. Breeders that violated the AWA could still claim that they had a clean inspection report. Teachable moments were not published on the agency’s website. This black-out prevented the public from learning if a pet store obtained puppies from breeders with violations of the AWA.

Only after the ASPCA filed a lawsuit against the USDA for abandoning its responsibility to enforce the AWA to ensure the humane care and treatment of commercially bred dogs AND a directive by the United States Congress did USDA inspectors finally start issuing written violations at puppy mills in 2022. The USDA also had to start posting inspection reports after three years of a total blackout.

Robert Hensley, legal Advocacy Senior Counsel for the ASPCA appropriately summed things up about the USDA’s “teachable moments” era: “The USDA refers to licensed dog dealers as the agency’s ‘customers’ and their deliberate refusal to enforce the law – even when licensees have subjected dogs to egregious suffering – demonstrates that the agency believes its customers’ interests always come first. The agency {USDA} has been asleep on the job and we’re asking the court to end the USDA’s customer service approach that has caused so much harm to the animals it has a legal and moral obligation to protect.”

According to Michigan, "While ineffective AWA enforcement has long been a concern, criticism of the agency’s (USDA) enforcement processes has grown in recent years. Regarding this goal, the plan indicated that “APHIS believes that collaborating with regulated entities is the best way to ensure compliance and help the regulated community minimize costs associated with non-compliance.” According to a former USDA assistant director of animal welfare operations, this policy resulted in “a systematic dismantling of [the] animal welfare inspection process and enforcement.”

Let’s never forget, for six long years, month after month, thousands of innocent dogs suffered from cruelty and neglect because the USDA was asleep at the wheel.

Bureaucratic Log Jam

To understand why the USDA can’t get out of its own way to ensure humane puppy mill conditions, consider its structure.

The United States Department of Agriculture has TWENTY-NINE agencies. TWENTY-NINE layers of bloat - with nearly 100,000 employees. 100,000 federal employees who can only be fired for cause, whereas in other, at-will employment situations, employees can be fired for any reason or no reason at all – as long as the termination does not violate local, state, or federal employment laws.

  • For each “cause,” of termination, the federal agency in question – and the United States Office of Personnel Management (OPM) – has a step-by-step action plan. As such, federal employees rarely get fired without notice. Talk about job security. Nice job if you can get it.

  • Believe it or not, there are FOURTEEN Deputy Administrators and/or Directors at APHIS the department that oversees puppy mill inspections. FOURTEEN APHIS Directors, each with his/her own assistants and clerical staff. So when a change is finally made to benefit animals, it must wade through a multitude of people, paperwork, and approval time.

It’s called bureaucratic bloat – and produces a logjam of inefficiency where change comes as fast as molasses uphill in winter. And to top it all off, more than three veterinarians are admins within APHIS. Apparently, they have forgotten their graduation oath. Especially when, yet again, another puppy mill with horrendous conditions makes the news.

The Veterinarian’s Oath
Being admitted to the profession of veterinary medicine, I solemnly swear to use my scientific knowledge and skills for the benefit of society through the protection of animal health, the relief of animal suffering, the conservation of animal resources, the promotion of public health, and the advancement of medical knowledge.

I will practice my profession conscientiously, with dignity, and in keeping with the principles of veterinary medical ethics.

I accept as a lifelong obligation the continual improvement of my professional knowledge and competence.

The saddest part of this whole story is that it’s the innocent dogs who must always suffer. Why must they endure cruelty in order to draw attention to the ineptitude of the USDA? What if the USDA reduced administrators/directors and hired more APHIS inspectors to monitor puppy mills? Oh, but that makes sense, doesn't it? So don't hold your breath.

It doesn’t take a brain surgeon to figure out the solution to this abomination called commercial dog breeding. Six states already have. New York, Maryland, Maine, California, Illinois, and Washington banned the sale of puppy mill puppies at pet stores. And 450 communities have done the same.

Some good news is the growing number of local grassroots groups like, and joining the fight to end the puppy mill pipeline. Their efforts are creating a ripple effect across America. Every month we're closer to that tipping point – when enough Americans learn the truth behind that cute puppy in the window or in that online puppy-for-sale ad.

Dog lovers and animal welfare advocates eagerly await the day Americans truly understand why visiting local shelters, rescues, and reputable breeders (who treat their dogs like family) for their next dog is the logical and humane choice.

It’s only a matter of time until the USDA won't have puppy mills on its to-do list because puppy mills will be extinct.

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