OIG Recommends Changes to City’s Animal Exhibition License & Permit Procedures

Following a series of complaints regarding the welfare of circus animals visiting Chicago and whether the City had adequate licensing and enforcement provisions in place for animal exhibitors, the OIG reviewed the City’s regulation of animal exhibitors.

The OIG’s review found that traveling animal exhibitors present a special enforcement challenge for the City given the fact that exhibitors often apply for an exhibitor’s license at the last minute and arrive just a few days before performing, providing little time for inspection or review of application materials.

However, the review also found that the City also has no deadline by which exhibitors must apply for the license, requires significantly less information from exhibitors than other major cities, and lacks the special inspection capacity that may be needed to identify issues specific to the animals included in a given exhibit.

“We learned that there was a statutory intent to ensure baseline standards are in place for public and animal health and safety relating to animal exhibitions – circuses in particular,” said Inspector General Joe Ferguson. “However, we found that due to multiple gaps and disconnects in the local, state, and federal regulatory structure, intent alone was not enough to protect the animals, their handlers, or the general public. By focusing on the City’s responsibilities, we hope our work furthers the City’s goal of protecting everyone involved, and ensure each reaps the benefits of clear compliance and effective enforcement.”
The OIG made several recommendations for the City to improve its animal exhibitor licensing and enforcement process.

First, to mitigate the short period of time available to inspect and address concerns with temporary animal exhibitors, the OIG recommends that Animal Care & Control (ACC), establish firm deadlines for license and permit application materials well in advance of the proposed event, as well as require significantly more information with the application than is presently required. Such information would include veterinary records, proof of the exhibitor’s United States Department of Agriculture (USDA) license, as well as the most recent inspection reports from the USDA or other jurisdictions. Currently, none of this is required by the City. This recommendation could be met either through new rules and regulations, or the executive director’s authority to establish procedures for the new temporary animal exhibition permit.

Second, the OIG recommends that ACC exercise its authority to promulgate rules and regulations regarding the specific requirements necessary to approve or deny a license or permit application in order to provide greater transparency and consistency in enforcement of the City’s animal welfare requirements. Currently, these rules and regulations are not in place.

Lastly, the OIG recommends that ACC provide additional training for its inspectors, or work with outside specialists, to ensure that all ACC inspections are conducted competently. Currently, not all inspections are performed by those who are trained in identifying issues specific to the animals included in a given exhibit.

In response to the report, ACC stated that it is currently reviewing best practices to develop the most appropriate permitting, inspection, and enforcement process for animal exhibitions in Chicago, and will work with the Law Department to draft rules and regulations for animal exhibitions. ACC also reported that future permitting and licensing will include stringent application deadlines in advance of the event as well as additional compliance requirements. Finally, ACC pledged to seek additional training for inspectors and veterinarians to identify issues specific to exotic animals included in Chicago exhibits.