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The following is the complete text of the 1998 evaluation of the Center for Animal Care and Control by the 
Humane Society of the United States [Part 5].



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ANIMAL HOUSING AND HUSBANDRY

Dog and Cat Housing
Dog and cat housing facilities at the Manhattan and Brooklyn shelters are antiquated, overcrowded and in 
very poor condition. However, the kennels at the Staten Island facility are quite good and are much more in 
line with what is currently considered acceptable within the animal control community.

In all five shelters, cats are housed in standard stainless steel cages lined with heavy brown paper. This type 
of arrangement is standard in many shelters. For the most part, cats are housed primarily in enclosed rooms, 
however in several areas, cats are temporarily housed (by default) in makeshift arrangements.

Caging for dogs at the Manhattan and Brooklyn shelters consists mostly of double-tiered wood and laminate 
enclosures that have been in use for some time. Many are approximately four feet by four feet, but most are 
approximately three feet by four feet. As a result in some areas, the top of a kennel is too low for some dogs 
to stand and move about freely. The cages are old and worn out with peeling laminate and separation of 
floors from the walls allowing water and urine to drip from one cage into the one below. In some areas, cages 
with a "lifetime warranty" are literally falling apart at the seams.

There are fiberglass "beds" in the cages which theoretically are to allow the dog to get up off of the floor and 
out of their own waste. However, many dogs do not seem to use the beds for this purpose. If the dog does 
not utilize the bed, the bed just acts to make the cage even smaller and cramped. Essentially, the cages 
themselves are just too small.

Recommendations: The quality of animal housing facilities is one of the most important aspects of preventive 
health care and disease control. A shelter with poor cage design, overcrowding, difficult cleaning conditions 
and poor ventilation will never be able overcome these obstacles, no matter how hard-working and dedicated 
the staff is.

Specific areas to consider for cats include the following:

Provide an adequate number of professional cages (such as stainless steel) that are at least three feet by 
three feet with solid partitions to prevent contact between cats.
Continue to develop plans to build or renovate space to house more cats. Attention should be given to 
separate areas/rooms for cats of different ages and life stages. Feral cats, when housed, also have special 
sheltering requirements including a quiet and escape-proof area for housing./29
Provide platform perches for all cat cages. Cats are "three-dimensional creatures" and perches expand the 
area of the cage for their use and comfort. Giving the cats a means of exercise and a place to sleep away 
from their litter boxes will greatly improve their attitude and well-being during their stay.
Offer cats some type of comfort item that can be theirs during their stay, such as a blanket, towel, shoe-box, 
or paper grocery bag. If the cat is moved from cage to cage, ensure that this item travels with them to their 
new location. This will increase the comfort and reduce stress levels of cats being sheltered, and will lessen 
the spread of disease./30


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FN29/ HSUS Animal Sheltering Magazine, "Free-Roaming Cats." September/October 1998.
FN30/ HSUS Shelter Sense, "Caring for Cats in the Shelter." March, 1995.`

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Significantly improving the dogs' housing situation will involve some major additional renovations to make the 
kennels as comfortable, appealing, safe and functional as possible. We recommend that a short term 
emergency maintenance program be budgeted sufficiently and implemented, while long-range plans for 
improvements are developed.

Specific areas to consider for dogs include:

Eliminate two-tiered caging for dogs from all future design plans.
Immediately repair kennels which are older and need work, such as those that need to be resealed and 
painted.
Retreat floors and walls of kennel areas with a lifetime sealant. Once completed, floors will be resistant to 
urine, fecal odors, and disease-causing organisms.
Immediately repair/replace damaged caging and guillotine doors.
NOTE: The HSUS was pleased to see the introduction of several renovated or new kennel wards during our 
visit, and are similarly pleased to hear that plans are underway to make additional improvements within the 
kennel housing. In addition, during our visit, HSUS E-Team members made a strong recommendation to 
eliminate two tiered caging, and we understand that the Executive Director has already taken this 
consideration into account by amending current CACC facility design plans. (See also within this section 
"Two Tiered Caging for Dangerous Dogs" and "Dangerous Dog Holding/DoH Cases.")

To implement many of the above recommendations will obviously result in the temporary unavailability of 
certain additional kennel areas during the improvement process. Clearly the benefits, however, far outweigh 
the risks. With proper planning, this process can be undertaken with minimal impact on shelter populations.

Flooring
Newer flooring throughout much of the animal holding areas in Manhattan and the Bronx is concrete with a 
non-skid (granular) epoxy surface, which reduces slip and fall but which is uneven and therefore difficult to 
clean and maintain with a squeegee or even a mop. In fact, the smell of urine was also prominent in these 
two shelters, and there appeared to be a slight urine residue on the floor in some kennel areas, especially in 
Brooklyn. This, however, seems to be primarily the result of an inappropriate flooring material rather than 
attributable to inadequate cleaning procedures.

Some of the older wards (from the time of the ASPCA) consistently had wet floors in need of improvement. 
This flooring is much smoother (and therefore extremely slippery when wet), creating an environment 
conducive to slip and fall.

Recommendations: It was reported that CACC facilities staff had recommended against the new flooring and 
that modifications are in the works for all areas. Several flooring manufacturers now carry newer materials 
that are very smooth and easy to clean but are also non-skid.


Heat/Cooling/Ventilation/Humidity
The HSUS E-Team members visited the shelters during a very mild time of year (70 degrees), and the 
temperature in the animal holding areas was adequate. The kennel staff themselves did not mention any 
animal-related problems specifically with temperature control in the buildings and none were noted. 
Ventilation was very poor in the Manhattan and Brooklyn shelters. At the time of The HSUS visit, there was 
almost no sensation of air movement, the wards always seemed to be wet and humid, and the floors never 
dried completely.

Condensation was evident on water pipes, with resultant dripping on floors confirming a serious imbalance in 
the HVAC (Heating/Ventilation/Air Conditioning) system. The HSUS was pleased to learn that new, improved 
HVAC systems are in the works for Brooklyn, Manhattan, and Staten Island.

Recommendations: Health examinations, rigorous sanitation procedures, and the careful handling of animals 
are responsible practices to prevent the spread of disease. However, proper ventilation and circulation, 
which should be supplied by some type of air-exchange system are a fundamental component to disease 
prevention protocols.

Ventilation seems to be one of the biggest facility needs by far at CACC facilities. Clearly, a lack of adequate 
ventilation certainly contributes to the incidence of upper respiratory disease in the cat wards and dog 
kennels. The CACC, in designing the ventilation system, should consult the most recent American Veterinary 
Medical Association (AVMA), United States Department of Agriculture (USDA), American Boarding Kennel 
Association (ABKA), and American Animal Hospital Association (AAHA) recommendations regarding room 
changes of air per hour. A total of 17 room changes of air per hour, without cross contamination of adjacent 
rooms, is the current standard.

A properly selected and installed air purifier is well worth the investment--it can remove 98 percent of the 
bacteria, viruses, odors, fumes, smoke, dander, and dust that pass through it (when properly maintained). Air 
exchange systems are especially important in fully enclosed shelters.

The most efficient air purifier is the High Efficiency Particulate Absorber (HEPA) system, which is used in 
human operating rooms. This system is designed to filter out extremely fine particulate such as viruses and 
bacteria. This system, if outfitted with a charcoal filter, also can be used to eliminate odors.

In general, the temperature at floor level for kittens and puppies should be at least 75 degrees. For adult 
animals, a temperature of 65-70 degrees is appropriate.

Sound Levels
Shelter renovations have resulted in increased noise levels in the Manhattan shelter (due to the temporary 
housing of animals normally housed in Brooklyn). New and renovated housing designs, however, will 
incorporate sound barriers to minimize noise levels.

While animals are separated by species to reduce stress resulting from noise, several doors into dog wards 
were left open, immediately adjacent to areas housing cats. In Manhattan, the noise levels in the treatment 
area were low, but noise in the euthanasia room was, at times, excessive.

Recommendations: To some degree, noise is inevitable and therefore evident in all animal shelters, large 
and small. Noise, however, not only can present a danger to staff, it plays a great role in forming the public's 
opinion of a shelter. No one wants to spend their time holding their hands over their ears, while trying to find 
the dog to spend their life with. Additionally, the short and long term effect on the animals must be 
considered.

Too often, animal shelters are noisy to a point of distraction for the staff, public, and the animals themselves. 
The barking of dogs is the greatest source of noise, but many factors contribute. Advancements in the 
design of shelters, and the materials incorporated in them, may help to "deaden" the noise in dog kennels. 
This "deadening" helps to take the edge off distracting noise. In addition, OSHA has strict regulations 
regarding acceptable decibel levels (particularly on a continual or routine basis) to protect employees.
For every shelter, we make the following recommendations:

Consider installing noise reducing panels which could be mounted above the runs. These panels refract 
sound and help to weaken the sonic signal before it reaches the ear. Their use would improve the 
environment for workers, animals, and visitors alike. Such panels must be specifically designed for 
application in a kennel environment. Otherwise, disease control issues may not be properly addressed.
Evaluate the sound levels within the kennel area, and continue to make earplugs available for staff use 
during cleaning and feeding to stay in compliance with OSHA regulations. The importance of policies 
regarding ear protection should be reiterated to staff. [Note: We understand that some kennel staff working 
with the more aggressive animals are hesitant or uncomfortable to have their sense of hearing decreased by 
earplugs. If this continues to be a concern, consider discussing the availability of alternatives with OSHA 
supervisors].
Animals who are recuperating from injuries or illness should have a quiet place to rest during their treatment 
or recovery period. If kept awake and on guard, due to the close proximity of barking dogs, their recovery 
period may be lengthened or even compromised. These animals should always be removed to a quieter, less 
stressful area of the building.
Special Mention Regarding Noise
The HSUS received a sample copy of a Double Compact Disc (CD) entitled "DogPoundFoundSound (Bad 
Radio Dog Massacre" [sic] which was recorded on June 21st, 1996 in Manhattan's Dog Adoption Wards 2A 
/2B and 3A/B. This CD is available and distributed via an internet web site./31 Materials enclosed within the 
CD mention that this effort is part of a larger photojournalistic campaign:

"....intended to alert the city's inhabitants to the fact that every month, thousands of discarded pets are being 
killed as routine procedure behind the walls of animal 'shelters' that essentially function as pet 
slaughterhouses . . . These CDs contain the sounds of dogs in acute distress." /32



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FN31/ http://brdm.org, Claude Matthews, 1998.
FN32/ CD insert from "DogPoundFoundSound(Bad Radio Dog Massacre."

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The HSUS listened to the abovementioned CD and found it to be similar to the noise found in almost any 
animal shelter's kennel area. While we did hear recordings of dogs barking, we believe the use of the term 
"in acute distress" to be overly dramatic. Animal care and control experts agree that no animal shelter, 
boarding kennel, or area where a large number of animals are housed is without a certain level of noise and 
barking.

Feeding/Food Storage
The HSUS E-Team members did not specifically observe feeding practices during our visit. But written 
protocol, confirmed by discussions with shelter staff, appears to follow HSUS recommendations, taking into 
consideration the animal's age, health and denotation. Cats and dogs are fed twice a day. Puppies and 
kittens are fed three times a day and nursing mothers are fed high calorie diets three times a day. Geriatric 
animals, and those with dental problems are fed soft food accordingly. Special feeding requirements are 
marked by either stickers or stamps. The CACC consistently uses one good-quality commercial food 
exclusively for feeding shelter animals.

Stainless steel bowls and disposable plates are primarily used, which promotes good disease control. Plastic 
bowls were observed in some cages, mostly with exotics, though in some cases, cats. Food is stored in 
separate areas. During our visit, the areas appeared to be in good order. However, evidence of flies and 
rodents leaves room for speculation as to how well food storage areas are maintained.

Recommendations: The HSUS commends CACC for using a good quality commercial brand food for the 
feeding of all shelter animals. It is clear that CACC management appreciates shelter nutrition as a priority. 
Many shelters rely on a variety of donated foods, but all shelter animals, regardless of their term of 
residence, should receive a good quality, balanced diet that is appropriate for their life stages. Because 
animals needing shelter are in a stressful situation, feeding one brand exclusively, especially a premium 
brand, cuts down greatly on the number of animals who have gastrointestinal problems while at the shelter.

The only concern is that food storage areas must be kept in such a way to discourage rodents and pests. 
Like most animal shelters today, The CACC apparently suffers from a rodent problem, and a consultation 
with an urban wildlife specialist should be considered to explore humane deterrent methods./33



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FN33/ HSUS "Wild Neighbors: The Humane Approach to Living with Wildlife," Fulcum Publishing, 1997.

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Cleaning/Disinfection
During The HSUS E-Team visit, it was impossible to observe cleaning in all of the shelters. Generally, facility 
tours occurred near the end of the cleaning schedule or well after it had been completed. However, 
observations and, more frequently, conversations with various individuals, shed light on current protocols 
and procedures.

Efforts are underway to create uniformly consistent cleaning protocols for all five of the shelters. For the most 
part, cleaning is scheduled so as not to interfere with the visiting public, however (especially during 
renovations) some of the larger wards simply cannot always be completed on schedule. Currently, the 
increased volume at Manhattan makes cleaning a day long activity.

Kennel staff are scheduled on two shifts, 8:00 A.M. to 4:00 P.M. and 4:00 P.M. to 12:00 A.M. In Manhattan, 
cleaning is done in the morning and again around 10:00 P.M. In the other shelters, it occurs primarily in the 
morning and after the closing of the facilities. Adoption wards are meant to be spot cleaned throughout the 
day.

In general, hoses with hydrofoamers containing a disinfectant called A464® are used to disinfect dog cages 
and runs. At times bleach is also used, such as when infectious diseases are suspected within the kennels. 
Spray bottles containing disinfectant are used for cat cages which are cleaned with rags. Various kennel 
technicians, however, however, had differing levels of understanding relating to both the use and limitations 
of disinfecting products.

Depending on the type of caging being cleaned, a variety of sponges, soft bristle, and hard bristle brushes 
are used for the most effective cleaning. During this process, cats are moved into carriers or open cages, 
and dogs are either moved to an empty cage or tethered to a stationary point in the kennel or various 
hallways. Some staff reported that animals are occasionally allowed to roam free during cleaning, although 
this option appears to be against policy in at least some of the shelters.

We understand that extra staff are scheduled to specifically monitor and keep clean the adoption wards, 
which is a good husbandry practice. HSUS E-Team members did, however, notice a few dirty cages in other 
areas which apparently went unnoticed by staff members busy with other activities.

The CACC facilities are making a transition from paper cage linings to raised platforms or thick and sturdy 
rubber mats. Many of these were present in cages and seemed to be preferred by both the animals 
themselves and cleaning staff. In the past, paper that was used to line the cages of larger dogs was often 
soaked during use and literally stuck to the cages, which has made cleaning much more labor intensive and 
therefore increased the potential for the spread of disease.

One of the most noticeable problems associated with cleaning was the dampness of cages and sometimes of 
the animals in them. This was most frequently noticed in Brooklyn and Manhattan and can be due to any 
number of causes or a combination thereof, including inadequate ventilation and improper drying of cages.

The cleaner conditions at the Bronx, Queens, and Staten Island shelters are commendable, however, in 
fairness to the staff of Brooklyn and Manhattan, there is really no comparison in terms of labor. These three 
shelters are significantly smaller, are significantly newer, and do not house the nearly the same volume or 
type of animals as the other shelters. The Bronx and Queens facilities have the additional fortune of not 
holding animals overnight.

General populations, DoH animal-holding and -quarantine, and isolation areas are cleaned in a logical 
sequence in order to prevent the spread of disease from one room to another. In general, sanitation appears 
to be quite good at the shelters we visited, given the limitations of the facilities. When possible, cage banks 
can be removed to the garage and cleaned with pressure hoses--which we observed at the Manhattan 
shelter.

Potentially dangerous dogs are most often housed in cages with guillotine doors which can be utilized during 
cleaning (to move animals from cage to cage without handling) as long as space is available. Otherwise, they 
must be lifted out and either tethered or restrained by a staff member while the cage is cleaned. (See also 
within this section "Two-tiered Caging for Dangerous Dogs" and "Dangerous Dog Holding/DoH Cases.")

Manhattan Drainage Systems
Disinfecting the two-tiered cages in Manhattan is simply an insurmountable task because of cage design. 
Original drainage systems were constructed to collect urine and water spills, routing to an enclosed gutter 
which was then meant to empty from a pipe into a drain on the floor. However, this system does not work. 
Instead, urine simply spills or drips out of incomplete pipes and splashes onto the floor -- sometimes from a 
height of two or three feet. The spill off then funnels slowly into a common drain in the aisle between the 
cages, which is unfortunately where the public and staff must walk. In those areas where the floor is 
substantially torn up, urine and water sits in pools. Not only does the evident smell of urine serve as a 
deterrent to the public, it is also a serious public health and safety hazard.

It is important to note that concerns regarding the faulty "flushing system" in the Manhattan shelter (and 
attempts to resolve them) have been well-documented by shelter experts for many years. In fact, 
documented problems with this system date back to days of ASPCA reign, reflected in an internal ASPCA 
memo dated September 1993, which noted that:

"The flushing system (where water purportedly cleans the rear trench drains) in not fully operational. This 
system has never worked properly. The original plan was for the system to work automatically at timed 
intervals -- this never happened for a variety of reasons. The manual operation is problematic at best." /34



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FN34/ Internal ASPCA memorandum from Julie Morris to John Foran, dated September 10, 1993 and 
provided to The HSUS by an outside community group in May, 1998.

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Recommendations: Any area of a shelter in which animals are housed or through which animals pass must 
be cleaned and disinfected daily. This includes, but is not limited to, examination rooms, holding rooms, 
animal holding areas, and front office. Circumstances and finances may affect the choice of particular 
cleaning materials and methods, but the daily cleaning schedule should be observed without fail. But 
because of the nature of animal shelters, however, cleaning could occur 24 hours a day in any facility and 
still be incomplete.

It is our understanding that CACC management is developing new cleaning protocols, and we are confident 
that these will be sound and effective. New protocols should be developed with the input of the individuals 
who do the cleaning and can put a practical spin on proposed procedures. With their input agreement, new 
protocols will also be much more likely to be carried out properly and consistently.

Another area which should be considered in any shelter is an occasional random evaluation of cleaning 
practices, perhaps even done by peers. It is easy to become complacent regarding cleaning and measures 
should be taken to ensure consistently high standards.

Regarding daily maintenance routines for keeping kennels and cages free of feces and urine: While we 
understand that adoption wards are a priority in terms of the public's perception, HSUS E-Team members 
believe strongly that the other animals deserve equal consideration in terms of kennel help and cage 
maintenance.

Communication with kennel staff must go beyond instruction of duty, and should include an explanation of 
why operational procedures are done the way they are. Additionally, individuals should not be given the 
responsibility to clean until their skill and understanding has been demonstrated. Cleanliness plays a major 
role in disease control, morbidity, comfort of the animal, and public opinion which in turn affects adoptions 
and overall reputation.

In reality, the effectiveness of disinfection is more a function of the time, effort and thoroughness spent 
disinfecting than anything else. For instance, effective cleaning of the front of a cat cage requires not only a 
good scrub brush but also a dedicated individual. Keeping animal numbers to a reasonable level, and 
therefore employee morale up, are also important factors to consider.

The HSUS suggests the following to all shelters:

For adequate disinfection of a kennels and cages
All kennels, cages, and runs should be thoroughly disinfected daily, including scrubbing daily with hot water 
and a disinfectant proven specifically effective against various bacteria and viruses common in a shelter 
environment (including distemper and parvovirus). Chlorine bleach (mixed with water in a 1:32 dilution) or a 
quaternary ammonium product are the two disinfectant choices most commonly used in shelters (see below 
for more information).

Disinfectants must be mixed according to specific manufacturer instructions.

Once applied, disinfectants must be allowed to remain in contact with the surface for the specific length of 
time recommended by the manufacturer before rinsing.
During cleaning, all animals should be placed in a separate holding area and should never be left in the cage 
or kennel. In addition, animals should not be exposed to water or disinfectant.
Food and water bowls must be considered potential disease carriers and should be cleaned, rinsed, and 
disinfected daily according to product instructions.
The drying of cages is as important as cleaning and scrubbing. Enclosures should be completely dry before 
animals are returned to kennels and cages.
Kennels should be cleaned from ceiling to floor, and all cage doors, etc., should be manually scrubbed. It is 
false economy--and a potential source of infection--to clean the walls of a run only to the height of the dog 
inhabiting a run. If any one section of the shelter is left unclean, disease can be easily transmitted.
Dog Kennels
It is recommended that the shelter staffs adopt the following cleaning protocol (or a comparable variation) for 
dog kennels on a daily basis:

1. Remove the animal, bedding, and all food and water containers from the run to be cleaned.

2. Remove all solid waste (feces, hair, etc).

3. Rinse away urine with hot water, and adequately rinse the entire run, floor to ceiling.

4. Using a stiff bristled scrub brush and a solution of detergent/disinfectant (following manufacturers' 
instructions), scrub all surfaces within the run including the floor, sides, resting board, and top. Gates on the 
runs should be cleaned and scrubbed on a daily basis.

5. Allow solution to stand for twenty minutes (or according to the manufacturer).

6. Thoroughly rinse all surfaces with a steady stream of water (preferably hot).

7. Dry the run as completely as possible using a squeegee and ventilation prior to returning animals to it.

8. Clean all other areas including the aisles, walls and ceilings regularly, as they can accumulate bacteria 
which lead to disease and odor problems./35



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FN35/ HSUS Animal Sheltering "How to Clean a Dog Kennel," July/August 1997.

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Cat Cages
Many of the sanitation and disease control considerations mentioned above in the "dog cleaning" section 
also apply to cats. We recommend the following protocol (or a variation) for areas housing cats:

1. Remove cat(s) to a clean cage. If portable carriers are to be used, each must be disinfected following each 
individual use.

2. Remove all bedding. If newspaper is used, dispose of it. If blankets, rugs or towels are used, they must be 
washed, disinfected and replaced daily.

3. Remove food/water dishes and litter pans. Wash and disinfect all prior to reusing. If litter pans are to be 
used for the same cat, scooping solid waste, and totally replacing litter when necessary is acceptable. 
(Disposable, paper litter pans that must be changed at least daily may be an alternative to consider).

4. Scrub all surfaces including the cage door with an appropriate disinfectant solution. Allow solution to stand.

5. Wipe cage dry; replace bedding; replace clean litter pan; replace food and fresh water; replace cat(s).

6. Clean walls, floors, between and tops of cages, windowsills and all other surfaces within the room./36



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FN36/ HSUS Animal Sheltering "How to Clean a Cat Cage," Sept/October 1997.

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NOTE: Shelters must pay special attention to the use, misuse, and overuse of bleach, especially within cat 
housing areas. Bleach is not only corrosive to objects (such as metal caging and clothing) but also has 
potentially harmful consequences. Bleach fumes can be irritating to the mucosa of cats' nasal passages and 
upper airways, and may even cause potential damage. Experts speculate that bleach can weaken cats' 
resistance to upper respiratory infections. There are several comparable quaternary ammonia products (or 
"quats") on the market that will eliminate most odors, viruses, bacteria, and parasites without many of the 
concerns associated with bleach.

In addition, general recommendations for CACC cleaning include:

Continually repair any hoses, equipment or access to hot water that would make cleaning easier and better.
Consider the regular use of high pressure water systems to more effectively clean the kennels.
Provide training for all staff on sound cleaning techniques and the philosophy of disinfection. Make all staff 
aware that following written protocols for disinfection procedures plays an important role in disease reduction 
for sheltered populations.
A room should be considered full to capacity when there is one cage or run left vacant. This allows animals to 
be transferred from a dirty cage to a clean one. If further design changes are being considered, the CACC 
might benefit from evaluating an "all in, all out" housing situations. This method provides one room for dogs 
and one room for cats that is always left empty. The rooms are steam cleaned and allowed to thoroughly dry 
before rotation on a set schedule. While both of the above recommendations result in a smaller number of 
available cages, this effort can dramatically lessen "critical mass," which in turn will reduce the likelihood of 
disease and contribute greatly to healthier shelter populations in the long run.

Lastly, and perhaps most importantly, the "against-protocol" practice of allowing dogs to run loose while their 
cages are being cleaned is dangerous for many reasons. Staff runs the risk of animals escaping through an 
open door, spreading disease, cage fighting with enclosed animals, and inciting general excitement or fear in 
the other animals. This also creates a hazard for both animals and the public if an individual (staff or public) 
were to open the door, unaware of the loose animal, allowing him or her to escape into the hallway. 
Additionally, a clear possibility exists that an animal could escape and get into a fight with another animal 
tethered in the hallway, easily endangering any individual attempting to break up the fight. The benefits that 
result from the staff's desire to give these animals an opportunity to have a bit of time to "be free to tear 
around burning off steam" combined with the convenience of empty cages during cleaning are far 
outweighed by the many serious ramifications that could happen as a result. This practice is unacceptable, 
and must be communicated to all cleaning staff and carefully enforced.

Special Recommendations Re: Cleaning Dangerous Dogs Housed in Two-Tiered Caging
During our visit, we were apprized of several situations which leave HSUS E-Team members reason to be 
concerned about staff safety and warrant immediate attention. Perhaps the greatest area of concern, 
brought initially to our attention by CACC management and later witnessed firsthand, is found within the 
current handling and housing of potentially dangerous dogs. Admitted either through the Department of 
Health (as quarantine cases), or through investigations (as "evidence" during cruelty cases, etc.), the CACC 
houses potentially dangerous animals for often indeterminate periods of time within an inadequate caging 
system.

Some members of the staff are significantly and legitimately fearful of many of these animals. For many 
years, animals were acquired by members of the public specifically for dangerous and aggressive tendencies 
(such as for dogfighting purposes) but have been primarily animal-to-animal aggressive, and not 
animal-to-human aggressive. In recent years, however, this is no longer solely the case. The emerging trend 
to maintain animals who are extremely aggressive toward humans as well as animals has been cause for 
concern for shelters across the country. The sheltering community is now struggling, faced with a need to 
humanely house and care for these animals, while at the same time providing adequate protection for 
care-taking staff.

To compound matters at the CACC facilities, there is a clear distrust of the physical kenneling facility, and the 
security of the cages used to house the more dangerous animals during their stay. For example, before 
entering certain CACC wards, we were advised to first observe through the small square window within the 
door before proceeding. There is a belief that the current stainless cage banks are simply not durable 
enough for the long term housing of the larger, more active, or dangerous dogs. In fact, doors have been 
known to come off after long term stress and weakening.

On more than one occasion, animals have been able to literally "break" out of their cages, and have been 
found running loose within a particular ward. During one portion of the visit, we ourselves observed a 
relatively small dog knock off his cage door, and then jump down from the upper level cage and run around 
within the kennel ward. Obviously, this presents several dangers to the staff, public, and the animals 
themselves. We could not confirm the frequency of this occurrence, however once is too often.

Another safety concern arises from the actual day-to-day cleaning and maintenance of the cages housing 
the more dangerous animals. While many of these cages are guillotined (for the purpose of allowing staff to 
provide two cages per animal during cleaning), this safety measure cannot be utilized. Because of the many 
animals housed within each ward, every animal is only provided one cage during their stay. In addition, many 
of the kenneling systems are two-tiered caging and some areas within the shelter are stacked three high.

For cleaning, the dogs in the top tier have to be removed manually by an employee standing on a step 
ladder who risks being bitten and scratched by the frantic dogs as well as suffering a serious injury from 
lifting or a fall.

Currently, the animals have to be removed, (lifted out at face level in the case of top cages) and physically 
restrained (using various methods) while the animal's cage is cleaned. Obviously, this was considered a very 
undesirable job amongst kennel staff interviewed. One staff member emphatically described that the newer 
stainless steel cage banks (especially three-tiered) necessitated using a stool to remove animals ( both cats 
and dogs). Also mentioned was the lack of stability provided by the foundation of these stainless steel cage 
banks, especially when moving larger, fractious dogs. It is our understanding that the cages (especially those 
not fixed to the floor) move around and threaten to topple, though it was unclear whether this occurred 
frequently.

Recommendations: It is important to note that CACC inherited these facilities during the transition from the 
ASPCA, and that current CACC management has made rectifying this situation a top priority. We were 
impressed to learn of the continued use of panic necklaces and panic buttons for kennel staff in the 
dangerous dog ward of the Manhattan shelter, however, it was unclear how widespread the use of this 
system is. We feel it should be utilized to its full capacity including drills which give all staff practice and 
familiarity in responding to a situation in which a fellow staff member is in serious danger. The very fact that 
such an alarm system is needed, however, illustrates the severity of the current kenneling situation.

We are quite pleased that CACC management is working diligently to address the many concerns associated 
with a problem that clearly cannot be solved overnight. It is our understanding that many of the cages used 
within the facilities are under a lifetime warranty, and that meetings with manufacturers on-site to discuss the 
current status resulting from wear and tear, replacements, and if necessary, alternatives have been 
occurring and will continue.

The significantly large population of potentially dangerous dogs which the CACC holds is something the 
CACC needs to seriously evaluate, as this is an area which hinders operational effectiveness on many levels. 
From a safety perspective, the CACC has been incredibly lucky until this time. We fear that this luck, 
however, may have resulted in a false sense of security from those individuals who do not have day to day 
contact with the more fractious and dangerous animals.

In addition, comments from kennel staff throughout our visit suggest that great reliance is placed on the 
capability of certain handlers and kennel staff who have demonstrated success with the potentially 
dangerous animals. Comments pointed toward certain individuals as being "the only ones who could handle 
the bite cases" and so forth.

While respect and pride in staff and their abilities is admirable, in this arena it can border on irresponsible 
and even dangerous, especially if it is also recognized or encouraged by CACC upper management. Such 
reliance will be substantially diminished by staff turnover, affecting the CACC's ability to attract and maintain 
new or additional help. It also threatens to set up a scenario in which staff who are afraid of certain animals 
are shamed into handling them in order to obtain that level of respect, putting themselves and others at risk.

This type of dynamic cannot be changed through staff meetings and memos. It must be eliminated through 
procedural changes. For example, cleaning protocol must be in place which does not rely on the "luck" of 
one person. If this requires leaving more open cages to utilize the guillotine door, than this must be a priority 
and must receive backing from the Department of Health. Potentially dangerous animals must be housed 
only in cages or runs which facilitate ease of cleaning and safe handling.


Two Tiered Caging for Dogs
The HSUS is strongly opposed to the multi-tiered caging system for dogs needing shelter. These types of 
cages for housing dogs, especially dangerous ones, are not only considerably confining, but extremely 
dangerous in a shelter setting. At a minimum, cages should allow for normal postural adjustments, with 
additional space for exercise. A cage enclosure (rather than a kennel) is largely only acceptable for cats, 
certain wild animals and exotics, toy and small breed dogs, small mammals, and/or for temporary observation 
during medical treatment.

A dog's physical and behavioral attributes warrant housing in "runs," not cages. In addition, a sense of height 
has been known to enhance a sense of power among animals with a predisposition toward aggressive 
behavior. It is not uncommon for a dog considered "manageable" in the past to quickly become a "furry 
demon defending his turf" following placement in an upper level cage. In addition, some cats tend to become 
aggressive and difficult to handle when they are able to take a "vulturistic" view of the world. A shelter 
worker's skills, strength, and defense mechanisms are all weakened when attempting to handle a dog at eye 
level, and bite wounds specifically on the face and neck are most often quite serious.

The above recommendations should be considered among criteria for new cages which will be used following 
renovations. The occurrence of dogs escaping must be investigated along with the reasons this happens so 
that measures can be taken to remedy the situation. Some measures can be taken immediately for little 
expense. We observed the use of cage clips on some of the runs. This should be instituted more uniformly, 
especially if investigation shows that doors are easily opened by animals of all sizes. Reliance on those staff 
with a reputation for expertise in handling animals may better be utilized by having them share their skills with 
others through involvement in staff training, especially new workers. Rescue drivers who are responsible for 
initial handling of many of these animals should also be consulted to share their skills. This will provide an 
opportunity to highlight staff talent. Additionally, standardized, safe, and humane practices should be 
implemented and closely monitored./37



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FN37/ HSUS Animal Sheltering, "Dogfighting: Sheltering the Victims." July/August, 1997.

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Hazards are not limited to human and animal interaction. To best address occupational hazards and 
acceptable strategies, we recommend a systematic and proactive evaluation of the shelters (including 
renovation plans) through another consultation with the Occupational Safety and Health Association (OSHA). 
Developing a plan to come up to speed with the federal regulations and recommendations specifically 
relating to animal shelters prior to any further renovations of shelter facilities is crucial to prevent any 
inadvertent violations that may appear down the road.

Dangerous Dog Holding/Department of Health (DoH) Cases
There are a large number of dogs held in the Manhattan and Brooklyn shelters under Department of Health 
holding for rabies quarantine ("bite cases") and/or awaiting dangerous dog hearings. As is the case in many 
large cities, the systems of oversight are seriously backlogged, and animals take a low priority.

In addition, the staff at CACC informed The HSUS E-Team that while the DoH protocols require the testing of 
all potential wildlife vectors (regardless of exposure) for rabies examination, they are hesitant to test all 
suspect dogs and cats (who have bitten or otherwise exposed a person or animal). Pragmatically, this means 
that with wild animals, CACC must: a) euthanize every wild raccoon, skunk, and bat it receives; and b) 
remove the heads (except bats) for rabies examination. Yet with dogs and cats, stray animals are held for a 
full ten-day quarantine, rather than providing euthanasia and testing after the two-day, stray period. This 
results in a large number of dogs being held for a minimum of eight additional days above and beyond what 
is truly necessary.

The recent audit by New York City's Office of the Comptroller, Bureau of Financial Audit included an analysis 
of the holding of animals who had bitten either humans or other animals. Portions worth noting are included 
here:

During the course of our audit, CACC officials informed us that DoH did not approve the timely release of 
animals that had bitten humans, or other animals. CACC refers to these cases as "bite holding cases." 
According to CACC officials, these delays caused CACC to incur extra boarding fees. To determine whether 
this was the case, we obtained a listing from both DoH and CACC of all bite holding cases processed during 
calendar year 1997. With the assistance of our statistician, we selected a random sample of bite holding 
cases for review. We analyzed those cases where animals were held by CACC 13 days or longer (allowing 
two additional days for weekends and holidays) and determined the related boarding costs.

Delays in DoH's Processing of Bite Holding Cases
We found delays in DoH's processing of cases involving animals that were being held in CACC's shelters to 
be examined for rabies. As a result, CACC had to board certain animals for extended periods of time, which 
is a burden on CACC's shelters since they have only limited space for the many animals they provide shelter 
for. In addition, these delays resulted in CACC spending a projected $14,575 in additional boarding costs 
during calendar year 1997.

Section 11.65 of the New York City Health Code states:

". . . when a person is bitten by a dog or other animal subject to rabies,. . . .The person who owns, possesses 
or controls the animal shall be required to confine and observe the animal in custody for a period of ten 
days."

To comply with the New York City Health Code, DoH'S Bureau of Veterinary Public Health Services 
dispatches a New York State Licensed Veterinarian from its staff to examine all animals involved in bite 
holding cases housed at CACC's shelters. Concurrently, CACC's veterinarians (who are also New York State 
Licensed Veterinarians) examine the animals, treat them for illnesses, and observe them daily. However, 
CACC's veterinarians are not approved by DoH to declare animals "rabies-free" and to authorize their 
release. DoH requires that a veterinarian (employed by DoH) see each animal at least twice before DoH can 
declare the animal "rabies-free" and authorize the release of the animal. In cases involving administrative 
holds, CACC may be required to retain the animals beyond 10 days.

We reviewed 282 of the 1,963 bite holding cases processed by DoH during calendar year 1997. We found 
that in 61 of the cases the animals were held by CACC for 13 days or longer. (To be conservative, we 
included two additional days beyond the normal 10 day holding period to allow for weekends and holidays.) 
Of these 61 cases, 23 involved administrative holds that justified the additional boarding days. The remaining 
38 animals had to be held at CACC's shelters for extended periods of time because CACC could not release 
the animals until they were declared "rabies-free" by a DoH veterinarian. Based on these results, we project 
that DoH's delay in processing bite holding cases resulted in CACC providing an additional 972 boarding 
days for animals involved in bite holding cases, and incurring an additional $14,575 in related boarding costs 
during calendar year 1997.

Given its limited resources, CACC needs to work closely with DoH to ensure that bite holding cases are 
processed in a timely manner. By minimizing processing delays on these cases, CACC will have more 
resources and space available at its facilities to provide food and shelter for the thousands of stray and 
abandoned animals in New York City.

Audit Recommendation: DoH should work closely with CACC to process bite holding cases within 10 days. In 
this connection, DoH should consider allowing CACC's New York State Licensed Veterinarians to determine 
whether the animals are "rabies-free" and to authorize their release or hire an additional veterinarian.

DoH's Response: DoH officials stated: "DoH has begun to work closer with CACC to process bite holding 
cases immediately after the required ten day time period needed to observe the health status of biting dogs 
and cats. As of April 13, 1998, DoH computerized all CACC holding cases to better track these biting animals. 
A pilot is being conducted to review the effectiveness of this tracking system through June 30, 1998."

DoH disagreed with allowing CACC's Veterinarians to determine whether the animals are rabies-free. DoH 
officials stated they "believe that the determination that an animal is rabies free is a public health function 
which should not be delegated. Instead, we have taken the following action. The Department has issued a 
posting, dated May 8, 1998, to hire a City Veterinarian (P/T) in order to increase our capacity to inspect and 
observe biting animals at the CACC Brooklyn and Manhattan Shelters."/38



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FN38/ Audit Report on the Financial Practices of the Center for Animal Care and Control; City of New York 
Office of the Comptroller, Bureau of Financial Audit, FM98-093A, June, 1998.

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Recommendations: This area of an animal control operation has an extremely high potential for exposure to 
liability. In addition, the handling of bite cases must be carried out with extreme care and sensitivity. Owned 
animals being observed (or tested) for rabies must be handled responsibly and with compassion./39 Yet 
while the threat of rabies is a serious one, we believe that the risks associated with DoH's strict oversight 
over CACC quarantines far outweigh the benefits.



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FN39/ HSUS Animal Sheltering, "In Practice" on Indiana animal bite and quarantine materials and 
recommendations, March/April, 1998.

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The HSUS has to agree with the auditor's recommendation to allow CACC veterinarians the ability to 
determine quarantined animals as "rabies-free." Even the 1998 Compendium of Animal Rabies Control 
(whose purpose is to provide recommendations to "serve as the basis for animals rabies control programs 
throughout the United States" ) does not encourage the strict oversight mentioned by DoH- instead it merely 
suggests that "any illness in the animal be reported immediately to the local health department [emphasis 
added]."/40 Most jurisdictions around the country allow licensed veterinarians within the community to 
perform this service, and some charge animal care and control officers with this responsibility.



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FN40/ 1998 Compendium of Animal Rabies Control, Suzanne R. Jenkins, VMD, MPH, National Association of 
State Public Health Veterinarians.
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As mentioned in the audit, clear financial ramifications exist as a result of housing animals awaiting post 
quarantine examinations. But perhaps more important is the fact that the animals themselves most often pay 
the price. Each animal awaiting disposition suffers stress as a result of additional holding, and uses a 
much-needed cage in a CACC facility.

The combination of overly strict holding requirements with routine backlogging on already overburdened 
shelters has a multitude of serious consequences: a) the overcrowding of shelter facilities; b) the euthanasia 
of good adoption candidates in order to make room for quarantine and holding; and/or c) pathological, 
stereotypical behavior of animals (due to continual confinement) as they await decisions regarding their fate.

Especially in situations beyond their control, it is discouraging for shelters to imagine that animals may be in 
worse physical and emotional health during sheltering than they perhaps were at the time of impound. We 
have often heard it said that if those in charge of disposition orders/decisions (such as judges and lawyers) 
could see the tangible results of extended confinement on those animals we deem companions, that 
determinations would be made much more quickly and succinctly.

Rabies Testing Procedures
Cephalectomy (the decapitation or removal of heads for rabies testing) is done using standard methods and 
personnel protection. Procedures and safeguards are in place to assure proper identification of the animals.

Recommendations: Many shelters are charged with euthanizing rabies-suspect animals and removing their 
heads for testing. Performing this procedure is unpleasant, and for many shelter workers, more stressful than 
euthanasia. Any improvements that can be made to make this process easier should always be implemented.

Knives and saws should be sharpened regularly, and surgical blades should be always available. Protective 
gear should always be worn, and instruments and contaminated surfaces should be cleaned and disinfected 
thoroughly./41



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FN41/ HSUS Shelter Sense, "Rabies Control and Your Shelter." September, 1995.
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Disease Control/Traffic Flow
Human and animal traffic flow throughout each shelter could be better, but renovations have incorporated 
smooth transitions from section to section. Extensive protocols have been established to minimize 
cross-contamination, but for such a large metropolitan area caring for such a massive number of animals, it 
is unrealistic to expect that there would be completely separate ingress and egress of animal populations. In 
many of the rooms, there is cross-traffic in the hallways between healthy and potentially contagious animals. 
But because there is such constant traffic (both human and animal), it is easy to understand why disease 
control protocols are crucial within each shelter.

Recommendations: Traffic flow (human and animal) can be improved to both encourage adoptions and 
discourage the spread of disease. For example, special attention in future designs can provide public routing 
throughout the kennels that flows from those with the least immunity (such as puppies and kittens) to those 
who may be potential carriers of disease (such as strays).

In an effort to encourage the adoption of adult animals from shelters, some agencies now "hide puppies" the 
same way grocery stores hide milk in an attempt to encourage the impulse acquisition of other products. Yet 
while viewing adult animals first might have advantages from a marketing standpoint, it certainly is not 
pragmatically appropriate if it in turn serves to spread potential disease to young animals with little immunity.

In future designs, consideration should be given to prevent staff and the public from spreading disease 
during routine operations. Efforts should be made to flow and divide kennels carefully to limit the entry and 
exit from isolation directly to kennel areas. With additional thought in future designs, traffic concerns can be 
minimized.

Many people do not realize the fact that most of the sick animals in an animal shelter arrive that way. People 
tend to think that if an animal gets sick at the shelter, then s/he must have been exposed there. On the 
contrary, in many cases, it is because an animal is sick that s/he is initially presented to the facility. In 
addition, many animals are stray for some time, wandering the streets (consequently getting exposed to 
disease) before receiving care by a good Samaritan who brings them in for assistance and care.

There are periodic outbreaks of diseases like parvo and distemper in the CACC shelters. These parallel 
outbreaks in the community, since dogs and cats entering shelters were among the general population. In 
general however, the incidence of infectious diseases does not seem to be a big problem at CACC. There is 
enough trained staff to identify an epidemic in the early stages and respond to it.

For the most part, testing and isolation is an adequate disease control measure. In cases of highly 
transmissible infectious disease (such as parvovirus), euthanasia is often part of the solution./42 
Unfortunately, this is the nature of population medicine, and historically, the positive testing and euthanasia 
of all exposed animals is the primary way in which major worldwide veterinary diseases have been eradicated 
in this country.



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FN42/ HSUS Animal Sheltering, "Parvovirus: Stopping a Deadly Disease," July/August, 1996.

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Recommendations: Even the best shelter, by definition, will be an inherently unhealthy place. Animals enter 
from different locations with unknown medical histories and often little or no protection from or past 
vaccinations against disease./43 Animals who have been recently exposed to (and therefore able to spread) 
disease may show no initial symptoms upon examination during the incubation period.



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FN43/ HSUS Animal Sheltering, "Managing URI and Kennel Cough," January/February 1997.

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While it is impossible to totally prevent the spread of disease within the shelter setting, it is possible to reduce 
it. The need for good health care protocols is crucial, and the rationale is twofold: a) to uphold the shelter's 
responsibility to care humanely for animals; and b) to maintain the reputation of the organization as a 
well-run community resource.
Shelter animals must be housed in a way that minimizes stress, provides for their special needs, affords 
protection from the elements, provides adequate ventilation, and minimizes the spread of disease and 
parasites. For the most part, CACC does an excellent job overall of separating animals by species. Increased 
efforts, however, should be made to house them in "life-stage groups" as well--keeping animals who have 
different stages of immunity (such as young animals, nursing mothers, and sick or injured animals compared 
to fully vaccinated adults) well separated with this the shelter. In addition, written protocols and policies 
should be put into place and followed carefully by all staff.

[cont.]



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