Submit your comments on the USDA Dog Welfare Regulations By April 20, 2026
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Thank you for the opportunity to comment on this important rulemaking. I strongly support updating the federal standards governing breeding female dogs and the exercise and socialization of dogs covered by the Animal Welfare Act. This proceeding presents an important opportunity to modernize a regulatory framework that has not kept pace with contemporary veterinary medicine, animal welfare science, shelter medicine, and public expectations regarding the treatment of dogs. The notice correctly asks whether current standards reflect outdated assumptions and whether new scientific evidence supports stronger protections. The answer is yes.
For too long, many federal dog standards have been built around a narrow conception of care: food, water, sanitation, and minimum enclosure dimensions. Those inputs matter, but they are not sufficient measures of welfare. A dog can be fed, watered, and kept alive in an environment that still produces chronic stress, frustration, social deprivation, disease pressure, behavioral deterioration, and diminished quality of life. Modern animal welfare science has moved beyond a survival-only model. Widely accepted frameworks such as the Five Domains model recognize that welfare includes nutrition, environment, health, behavioral interactions, and mental state, and that animals should have opportunities for positive experiences—not merely freedom from extreme suffering.
Dogs are a domesticated, highly social species shaped through thousands of years of close association with humans. Research in canine cognition demonstrates dogs’ unusual responsiveness to human communication and social cues. Behavioral science shows that dogs form attachment relationships with caregivers, benefit from positive human interaction, and can experience distress when deprived of social contact, agency, or environmental stimulation. Regulations designed for a social companion species should not be based solely on what allows an animal to physically persist in confinement. They should be based on what allows that animal to live in a manner compatible with good health and normal behavioral function.
These harms are often cumulative and normalized. A facility may appear compliant on paper while dogs experience constant barking, inadequate exercise, chronic gastrointestinal disease, repeated respiratory outbreaks, barren environments, prolonged solitary housing, or years spent in cages that do not allow running, jumping, exploration, or meaningful choice. When these conditions become common, they can be mischaracterized as inevitable features of kennel management rather than recognized as preventable welfare failures. Federal regulation should reject that normalization.
The shelter medicine field offers a useful benchmark. Animal shelters often house dogs only temporarily, yet shelter medicine has increasingly recognized that even short-term confinement can produce measurable welfare harms if not mitigated through enrichment, behavioral support, exercise, positive handling, foster placement, and appropriate social housing. If temporary shelter environments require proactive protections, then commercial systems housing dogs for months or years should be held to standards that are at least as protective.
The same principle applies to breeding female dogs. Reproductive animals face distinct physiologic demands and medical risks associated with pregnancy, whelping, lactation, and repeated reproductive use. A modern regulatory framework should address these realities through stronger veterinary oversight, evidence-based nutrition, limits on breeding age and frequency, retirement planning, and prevention of hereditary disease.
The recommendations that follow are grounded in veterinary medicine, shelter medicine, behavior science, and practical animal care. They reflect a straightforward principle: dogs require more than minimum maintenance. They require exercise, enrichment, disease prevention, social connection, freedom of movement, appropriate medical oversight, and pathways to normal living environments. This rulemaking is an opportunity to align federal policy with that evidence.
I strongly support updating the federal standards governing breeding female dogs and the exercise and socialization of dogs covered by the Animal Welfare Act. This rulemaking presents an important opportunity to replace outdated minimum standards with modern, evidence-based protections that reflect current veterinary medicine, animal welfare science, and shelter medicine. The APHIS notice specifically seeks information on outdated standards, new science, care of breeding females, and the exercise and socialization needs of dogs.
The existing framework remains overly focused on minimal maintenance inputs, such as food, water, sanitation, and enclosure dimensions. Those are necessary, but they are not sufficient. Modern welfare science recognizes that welfare includes physical health, behavioral opportunity, social relationships, and mental state. The widely used Five Domains model evaluates nutrition, environment, health, behavioral interactions, and mental state, and emphasizes positive experiences—not merely survival. (https://www.mdpi.com/2076-2615/10/10/1870)
Dogs require more than survival. They require opportunities to move freely, exercise, explore, play, form social bonds, receive veterinary care, and live in environments compatible with their biology as a domesticated social species.
In addition, USDA should use this process to encourage a broader shift toward access-to-care-based research and clinical innovation that provides diagnostics, treatment, rehabilitation, and direct benefit to animals who need care, rather than outdated vivarium-based systems in which dogs may be bred or confined without an independent advocate focused on their individual interests.
I. Care Considerations for Breeding Female Dogs
A. Breeding females require additional veterinary oversight
Breeding female dogs face distinct physiological demands and medical risks beyond those of non-breeding animals. Pregnancy, parturition, and lactation are associated with increased risk of dystocia, mastitis, metritis, postpartum complications, body condition decline, and neonatal loss. Veterinary references identify periparturient disorders in bitches as significant health concerns requiring monitoring and timely intervention. (https://www.ncbi.nlm.nih.gov/books/NBK562724)
APHIS should require a documented reproductive-health program, including:
pre-breeding veterinary examination
body condition scoring
dental and orthopedic assessment
vaccination and parasite review
pregnancy monitoring
whelping emergency plan
postpartum examinations
lactation monitoring
retirement criteria based on health
rehoming plan after breeding career ends
B. Nutrition during pregnancy and lactation
Pregnancy and lactation substantially increase nutrient and energy demands. Reproductive females should receive complete and balanced diets appropriate for gestation and lactation, with regular reassessment of body condition and caloric needs. Failure to meet these needs can compromise maternal and neonatal health.
APHIS should require:
diets appropriate for gestation/lactation
regular body condition scoring
individualized feeding plans
unrestricted clean water
supplementation only when medically indicated
C. Breeding age, litter frequency, and lifetime reproductive burden
Age at first breeding, age at final breeding, and breeding frequency are welfare-relevant variables recognized in modern animal welfare assessments. Excessively early breeding, advanced-age breeding, and repeated litters without adequate recovery may increase cumulative health burden.
APHIS should require:
No breeding before physical maturity
Veterinary clearance for older females
No continued breeding when health declines
Minimum recovery intervals between litters
Lifetime litter caps
Retirement based on welfare indicators, not productivity alone
D. Breed size and conformation
Breed size and conformation can materially affect breeding risk. Some breeds face an elevated risk of dystocia, chronic respiratory disease, orthopedic disease, or conformation-linked inherited disorders. Regulatory standards should account for these predictable risks rather than treating all breeds as physiologically equivalent.
E. Heritable defects and genetic testing
Inherited disease is a major preventable cause of suffering in dogs. Where validated tests exist, responsible screening can reduce disease prevalence, lower long-term veterinary costs, and improve welfare outcomes.
APHIS should require:
breed-relevant genetic screening for serious inherited disease
transparent health records
prohibition on breeding dogs affected by severe hereditary disorders
veterinary review of results
breeding decisions based on health, not solely market demand
II. Exercise, Enrichment, and Socialization
A. Shelter medicine demonstrates that enrichment is essential
Animal shelters often house dogs temporarily, yet shelter medicine has evolved to recognize that confinement alone can rapidly produce stress, frustration, repetitive behaviors, excessive barking, withdrawal, and behavioral deterioration. The shelter field now treats enrichment, behavior support, and positive human interaction as core welfare needs. If temporary shelter housing requires these protections, then dogs housed for months or years in commercial facilities should receive standards that are at least as strong—and often stronger. (https://static1.squarespace.com/static/5b92240775f9ee72cbaeeda1/t/64a88655f6d1b666bf7a614c/1688766038081/Gunter_Feuerbacher_ASPCA_Chapter.pdf)
B. Required enrichment programs
APHIS should require written enrichment plans for every facility, including:
Food puzzles and foraging opportunities
Scent enrichment
Toy rotation
Training and learning sessions
Novel environments and exploration
Predictable routines
Opportunities for choice and control
Environmental complexity and enrichment are consistently associated with improved welfare in kenneled dogs.
C. Positive human interaction
Studies in kennel and shelter settings show that positive human interaction can reduce stress-related measures and improve behavior. Familiar, calm, reward-based handling should be a required component of dog care—not an optional enhancement. (https://journal.iaabcfoundation.org/enrichment-involving-human-interaction-saves-lives-2/)
APHIS should require daily positive human interaction, including:
Gentle handling
Reward-based training
Calm social time
Grooming when appropriate
Low-stress husbandry
D. Social contact with other dogs
Many dogs benefit from compatible social housing or structured social contact with conspecifics. While not every dog is appropriate for group housing, prolonged solitary housing should not be the default. Social deprivation is a recognized welfare risk for a social species.
APHIS should require:
Compatible pair or group housing when appropriate
Structured dog-dog interaction when safe
Behavioral assessments
Documented justification for long-term solitary housing
Compensatory enrichment and human contact when separation is necessary
E. Exercise standards should be meaningful
Exercise cannot be satisfied merely by standing, turning around, or pacing inside a cage. Dogs need locomotion, exploration, and varied movement.
APHIS should require daily exercise that is:
Beyond the primary enclosure
Tailored to age, breed, health, and pregnancy status
Sufficient in duration and intensity
Documented in records
Modified only with veterinary justification
Examples include walks, yard turnout, supervised play, scent work, and structured activity sessions.
III. Dogs Are a Social Species Adapted to Life With Humans
Modern science supports that dogs are not naturally suited to permanent cage confinement.
A. Domestication and co-evolution
Dogs were shaped through domestication to live alongside humans. Research in canine cognition shows dogs are unusually skilled at interpreting human gestures, gaze, and communicative signals. Their behavior has been shaped through long association with people.
B. Attachment bonds
Studies demonstrate that dogs form attachment relationships with caregivers and use humans as a secure base in novel or stressful situations.
C. Biological benefits of companionship
Affiliative human-dog interactions are associated with beneficial physiological effects, including reduced stress responses and bonding-related neuroendocrine pathways.
D. Social deprivation harms welfare
Chronic deprivation of meaningful social contact can contribute to fear, frustration, abnormal repetitive behavior, and reduced well-being in kenneled dogs.
IV. No Dog Should Be Confined to a Cage Longer Than Medically Necessary
APHIS should adopt a clear principle:
No dog should be confined to a cage longer than is required to diagnose, treat, recover from, transport for, or safely manage a medical or emergency condition.
Long-term confinement of dogs in cages—whether singly housed or multiple dogs housed together in cage systems—is not acceptable housing for a social, active species.
The relevant welfare question is not whether a dog can stand up or turn around. It is whether the environment allows the dog to live in a way that is consistent with their normal behavioral needs. Modern welfare science recognizes that restriction of agency, movement, environmental interaction, and social opportunity can significantly impair welfare.
Dogs should be able to fully express species-typical behavior, including:
running
jumping
play
exploration
sniffing and scent investigation
choice of movement
retreat and rest in comfortable areas
learning and problem solving
positive interaction with humans
compatible interaction with other dogs
If an environment does not permit these behaviors on a daily basis, it should not qualify as acceptable long-term housing under federal standards.
Limited exceptions for cage use
Cage or crate confinement may be appropriate only for limited, documented purposes such as:
post-operative recovery
treatment of a medical condition
quarantine or isolation
brief transport
emergency evacuation
short-term safety management
clinically justified behavioral decompression
These uses should be time-limited and documented.
V. Move Away From Permanent Cage Confinement
APHIS should establish a regulatory direction that phases out permanent cage-based housing as the standard model.
Dogs in regulated facilities should have access to normal living environments and pathways to homes.
APHIS should consider requiring:
daily time in home-like indoor environments
regular outdoor access when climate appropriate
enriched group living systems instead of isolated cages
overnight foster programs
staff-home or volunteer-home rotations, where feasible
retirement and adoption plans for all non-breeding dogs
maximum cumulative time limits in primary enclosures
mandatory rehoming plans for retired breeding dogs
Permanent cage confinement should be the exception requiring justification, not the default model.
VI. Outcome-Based Welfare Standards
Compliance should not be measured only by cage size or feed bowls. APHIS should require measurable welfare outcomes, including:
body condition
injury rates
disease prevalence
fear and affiliative behavior
stereotypic behaviors
maternal health outcomes
puppy mortality
incidence of dystocia/metritis/mastitis
social behavior
retirement and rehoming outcomes
Outcome-based regulation is more consistent with contemporary welfare science than static engineering minimums.
VII. Incentivize Access-to-Care-Based Research
USDA should also prioritize publicly beneficial animal work that helps animals directly. Access-to-care-based research models can generate innovation while providing diagnostics, treatment, surgery, rehabilitation, and follow-up care for animals who need services.
This approach is more clinically relevant, more publicly accountable, and more consistent with modern expectations than outdated vivarium-based systems in which animals are confined primarily for institutional use without individualized advocacy.
VIII. Infectious Disease Prevention Must Be a Core Welfare Standard
APHIS should require every regulated facility to maintain and implement a written infectious disease prevention and response plan developed with veterinary oversight. Preventable infectious diseases should not be treated as an unavoidable feature of large-scale dog housing.
In many kennel systems, endemic disease becomes normalized. That is not an acceptable welfare standard. Conditions such as giardiasis, respiratory disease complexes, dermatologic infections, intestinal parasites, and preventable outbreaks should trigger corrective action. (https://caninewelfare.centers.purdue.edu/resource/managing-giardia-in-dog-kennels)
A. Infectious Diseases, such as Giardia should not be accepted as “normal”
Giardia is common in densely housed dog populations, including kennels and shelters, because it spreads efficiently through fecal contamination, contaminated surfaces, water, and reinfection cycles. But common does not mean acceptable. The fact that a disease is prevalent in a housing system may indicate flaws in sanitation, stocking density, drainage, hygiene, environmental design, or medical surveillance. Giardia can cause diarrhea, weight loss, chronic gastrointestinal disease, dehydration, and increased risk for puppies or immunocompromised dogs. (https://pmc.ncbi.nlm.nih.gov/articles/PMC545982/)
Recent literature has reported substantial prevalence of subclinical and clinical enteric infections in kennel-housed dogs, underscoring the need for active surveillance rather than passive acceptance of endemic infection.
The scientific article provided in this record likewise demonstrates that giardiasis has long been recognized as a management issue linked to environmental contamination, population housing, and control practices—not something that should simply be tolerated as routine. (https://pmc.ncbi.nlm.nih.gov/articles/PMC11078275/)
B. Required infectious disease prevention plan
APHIS should require facilities to maintain a written plan addressing:
vaccination protocols
intake health screening
routine fecal surveillance and parasite testing
Prompt treatment, and if needed, isolation of infectious dogs
diagnostic access for diarrhea, cough, skin disease, and unexplained illness
treatment protocols under veterinary supervision
cleaning and disinfection procedures
drainage and moisture control
potable water protection
ventilation standards
population density limits
pest and vector control
staff biosecurity and hand hygiene
outbreak reporting and response procedures
recordkeeping of morbidity, mortality, and recurrence rates
C. Environmental design
Disease control cannot rely only on medications. Facilities should be designed to reduce pathogen burden through:
non-porous cleanable surfaces
rapid feces removal
dry, cushioned resting areas
separation of elimination and feeding areas
adequate space to reduce contamination pressure
proper ventilation
quarantine areas
traffic flow that reduces cross-contamination
Giardia cysts can persist in damp environments, and reinfection is common when environmental management is poor. Effective control requires both treatment and environmental sanitation.
D. Welfare and disease prevention are inseparable
Repeated diarrhea, chronic parasitism, respiratory outbreaks, and endemic skin disease are not merely medical issues—they are welfare failures. A facility should not be considered compliant if preventable disease is routinely present, even when food bowls are full, and cages meet size minimums.
Recommended Regulatory Principle
No facility should normalize preventable infectious disease as the cost of doing business. If a condition is common because of the housing model, then the housing model should change.
X. Housing Scale, Group Size, and Facility Design Should Prioritize Small Social Units and Home-Like Environments
APHIS should not approach this rulemaking as an exercise in identifying the largest number of dogs that can be confined in a room while remaining technically compliant. The more appropriate welfare question is how housing systems should be designed so that large-number confinement becomes unnecessary.
Dogs should primarily be housed in small social units or home-like environments, not large kennel rooms. As a domesticated social species adapted to living alongside humans, dogs generally fare better in environments that allow individualized care, meaningful social contact, lower noise burden, greater freedom of movement, and more normal daily routines than are typically possible in high-density kennel banks.
This principle is consistent with contemporary welfare science, emphasizing behavioral opportunity, positive social experiences, and environments that support good mental states rather than mere survival. The Five Domains model specifically recognizes environment, behavioral interactions, and mental state as central welfare domains. (https://www.aspcapro.org/resource/five-domains-model-animal-welfare)
Research on kennel welfare has repeatedly found that restricted, barren housing environments can impair welfare, whereas enrichment, social contact, and improved management can improve outcomes for kenneled dogs. Reviews of kennel dog welfare note that housing design and management are key determinants of behavioral and physiological well-being. (https://pmc.ncbi.nlm.nih.gov/articles/PMC6067676/)
Large-scale rooms containing many dogs often increase predictable welfare risks, including:
chronic barking and noise escalation
contagion of arousal and reactivity
sleep disruption
reduced ability to monitor each dog individually
delayed recognition of illness or injury
competition and social tension
greater infectious disease transmission pressure
reduced opportunities for calm human interaction
institutional rather than individualized care
Scientific Basis for Noise and Density Concerns
Kennel acoustics research has documented extremely high sound levels in dog housing environments, with barking as the principal source. One widely cited study found daytime peak sound levels regularly exceeded 100 dB and reached approximately 125 dB. These conditions may interfere with rest and contribute to chronic stress. (https://www.sciencedirect.com/science/article/abs/pii/S016815919601132X)
More recent research on barking interventions likewise describes excessive barking as a significant source of noise pollution in kennel environments with negative welfare implications. (https://pmc.ncbi.nlm.nih.gov/articles/PMC8772564)
Higher density can also increase infectious disease pressure. Studies of kenneled and group-housed dogs have documented substantial prevalence of enteric pathogens and emphasize the importance of sanitation, environmental management, and population controls. (https://pmc.ncbi.nlm.nih.gov/articles/PMC11078275/)
Scientific Basis for Small Social Units and Human-Oriented Housing
Dogs are a domesticated social species shaped through close association with humans. Comparative cognition research shows that dogs are unusually responsive to human communicative cues and social signals. Attachment studies further show that dogs form caregiver bonds and use humans as a secure base in novel or stressful settings. These findings support housing models centered on meaningful human contact rather than chronic institutional isolation.
Studies in kennel and shelter settings also show that positive human interaction can reduce stress-related measures and improve behavior. (https://pubmed.ncbi.nlm.nih.gov/16430930/)
Precautionary Group Size Standard
Because there is no single universal biological threshold that applies to every building design and management system, APHIS should adopt a precautionary management standard rather than wait for perfect precision.
A reasonable starting framework is:
maximum of 8 dogs per shared housing zone as the default limit
lower limits when welfare indicators are poor
exceptions only when a facility demonstrates excellent welfare outcomes in enriched, well-managed systems
This proposed cap is offered as a precautionary welfare standard, not as a claim that 8 is a fixed scientific threshold in every circumstance. It is a practical limit intended to reduce the risks associated with crowding, noise, disease spread, and loss of individualized care.
Functional Housing Zone Definition
The relevant unit should not be labeled only as a “room.” APHIS should regulate any shared acoustic, visual, and airspace housing zone where dogs are exposed to one another’s noise, movement, pathogens, and social stimuli. A large warehouse divided by partial barriers may still function as one stressful housing unit.
Preferred Regulatory Direction
Facilities should be incentivized to transition toward:
small compatible social groups
home-like indoor living spaces
foster and overnight home programs
enriched indoor/outdoor housing systems
retirement and adoption pathways
individualized behavior and exercise plans
Core Principle
The goal of humane regulation is not to determine the maximum tolerable density of confined dogs. It is to create housing systems in which chronic large-number confinement is no longer the default model.
Conclusion
The science now supports a clear shift in federal policy. Dogs are highly social, cognitively complex animals shaped to live with humans and other dogs. They require more than food, water, and sanitation. They require health care, enrichment, exercise, social connection, freedom of movement, and pathways to normal living environments.
APHIS should modernize its standards by requiring:
enhanced reproductive care for breeding females
gestation and lactation nutrition standards
breeding age limits, recovery intervals, and litter caps
genetic disease prevention measures
daily enrichment and meaningful exercise
positive human interaction
compatible social housing whenever possible
prohibition of long-term cage confinement except for limited medical or emergency need
environments that allow running, jumping, playing, and exploration
outcome-based welfare monitoring
retirement, foster, and adoption pathways
incentives for access-to-care-based research
mandatory infectious disease prevention plans with surveillance, sanitation, isolation capacity, and zero tolerance for normalizing endemic preventable disease, such as Giardia
Noise and population limits
This is an opportunity to replace outdated minimums with standards that reflect current science and the public expectation that dogs be treated in alignment with their best interests.
