Doug Fakkema's March Report
FINDINGS and RECOMMENDATIONS to the
CITY of SAN ANTONIO
DEPARTMENT of ANIMAL CARE SERVICES
International Training Manager
Saving Animals Across Borders, SM
On Monday through Thursday, March 20-23, 2006 , I visited San Antonio Animal Care Services (ACS) in order to observe and evaluate operations and to provide staff training in animal handling. On Monday I spent from 6:30 to 11:30 in the kennels observing euthanasia, intake, unloading and cleaning. From 11:30 to 3:30 I accompanied an ACO on his scheduled shift. On Tuesday, Wednesday, and Thursday, I presented 4-hour workshops on animal behavior and handling to kennel workers and ACOs. Included in each day's training was a hands-on lab demonstrating actual equipment and techniques for handling feral cats and fractious dogs.
ACS is out of date in terms of how it conducts the business of animal care and control (operations). ACS is also out of date in terms of the equipment it uses to conduct the business of animal care and control.
ACS is also inefficient in its use of personnel and available equipment1. Much of the inefficiency is due to operational policies and procedures, both written and unwritten, which reflect outmoded or simply nonsensical ways of conducting business2. The use of outdated equipment contributes to the observed inefficiency.
In this document, 18 areas in need of change are identified. Eight are labeled "Implement Immediately" and the remaining 10 are labeled "Important" and should be addressed as soon as resources and time permit.
This document makes frequent reference to generally accepted industry standards (GAIS) as well as best, acceptable, and unacceptable practices3.
A note on change: if not managed properly, change itself becomes a problem. There have been recent examples of procedural changes that were put into place without proper notice, training or the equipment needed to make the change happen safely and smoothly4.
Implement immediately (no rank order)
1) RECOMMENDATION: Stop tagging feral cats tape tag to paperwork.
FINDING: ACS policy requires all cats (including feral cats) be tagged with a red ID tag. In order to follow procedure, the cat must be handled; this is a dangerous procedure for kennel staff and an extremely stressful event for the cat. Industry standard is that feral cats are NOT tagged. They are netted and placed in individual feral cat cages and except for food, water and cage cleaning, left alone for the duration of their stay.
FOLLOW UP: ACS Manager Sam Sanchez states that tagging of feral cats "is no longer required" (in an email dated 3-31-06).
2) RECOMMENDATION: Eliminate (pyrethrin/pyrethrum) dipping of animals. Other parasite control measures are more effective and available as needed. Do not build dip tanks in the new shelter.
FINDING: During certain times of the year, all dogs coming off the field services trucks are dunked in a dip tank prior to kenneling. This necessitates snare poling and dragging the unwilling dog in and out of the dip tank. GAIS is to use alternative flea and parasite control measures as needed. (Note: I checked with two professional shelter veterinarians5, both from southern states. Both felt very strongly that dipping as a standard procedure for all incoming animals is both out of date and unnecessary to control parasites. Dipping, they say, can be appropriate for extreme individual cases to control parasites depending upon the dip used.) Several ACS shelter workers commented that even after dipping, fleas are still in abundance. Plans for the new shelter include dip tanks in each of the kennels. I recommend that the plans be changed and the dip tanks eliminated.
3) RECOMMENDATION: Install restraint gate in euthanasia room.
FINDING: The actual restraint gate is in the EBI room, but as of my visit was not installed.
4) RECOMMENDATION: Discontinue current pre-euthanasia sedative and replace with GAIS pre-euthanasia anesthetic 5:1 ketamine/xylazine compound.
FINDING: ACS' euthanasia practice is below industry best practices and in some cases is unacceptable practice. According to ACS veterinarian Dr. Gonzales, the pre-euthanasia compound used is a mixture ratio of 2 mL ketamine HCL (200 mg) and 50 mL xylazine HCL (5000 mg). If administered according to the EBI room posted dose6, it is insufficient to produce true anesthesia. EBI GAIS calls for animals to be anesthetized (not sedated) when the individual situation warrants. The pre-euthanasia compound commonly used throughout the industry is a mixture ratio of 2 mL xylazine HCL (200 mg) and 10 mL ketamine HCL (1000 mg). When dosed according to GAIS7, the animal falls rapidly (3-5 minutes) into a state of deep anesthesia (not sedation). I was told by two ACS certified euthanasia technicians that policy permits intracardiac administration of sodium pentobarbital on animals injected with the supplied pre-euthanasia compound. This is unacceptable practice as the animals are merely sedated, not in a state of anesthesia, and can therefore experience pain as the needle is placed into the heart.
5) RECOMMENDATION: Provide cat restraint equipment for kennel attendant staff including: 1) Freeman Cage Net [Animal Care, Equipment and Services, Inc (ACES) FP-CC Freeman Cage Net W/Cover]; 2) plastic top loader carriers [ACES LB1 Small Animal Carrier 17x10x10] and encourage the use of already supplied Campbell Pet Company EZ Nabber [16" frame] and 3) cage Isolator [ACES TD-1 / TD-2 Isolator for trap #'s 30, 36, 42,48 & 60] for in-trap/carrier restraint of feral cats and raccoons.
FINDING: Prior to my animal handling training classes, ACS kennel attendant personnel were using a combination of snare poles, bite gloves and cat grabbers. Although at least 3 Campbell EZ Nabber nets were available to ACS personnel, there was little evidence that these devices were being used and strong evidence that little if any training had been provided on how to use them. Snare poles were still being used on feral cats, despite the policy prohibiting their use. I don't fault the staff for doing so as they had not been given training or safe and proper equipment for handling feral cats.
The blue plastic cat carriers used by kennel attendant staff are "pet" quality (designed for transporting personal pets to and from the vet), not animal control quality. Several of them were damaged and potentially unsafe.
6) RECOMMENDATION: Provide cat restraint/handling equipment for field staff including: 1) top/end loader cat carriers [ACES T18TE 18x9x11 Carrier Top & End Load & T24TE 24x12x14 Carrier Top & End Load]; 2) folding cat nets [ACES FN-LXK Folding, Extendable 4' Net]; 3) cat bags [Campbell Pet Company Cat Mesh Bags, 18x24].
FINDING: Animal Care Officer (ACO) personnel do not have proper equipment for handling cats, feral or friendly. Cats impounded by ACOs are placed into cages on the flat bed units that are totally exposed to the environment (except for a tin roof) and to other animals, usually dogs. By the time cats arrive at ACS they are completely stressed out often appearing feral. In addition, there is no safe or effective way to transfer cats trapped by citizens to the ACO vehicle, which results in occasional field escapes.
GAIS is to provide ACO personnel with metal cat carriers. The best cat carriers have both top and end loading capability (see #6 above). These carriers mate with traps [ACES 30D 30x9x11 Cat Trap w/rear door] and provide simple, safe and effective transfer and transport of cats in the field. ACOs should take enough carriers to their district to meet their needs. During unloading, the carriers (with cat) are easily and safely removed from the vehicle by kennel attendant staff and empty carriers put in their place.
ACO personnel should have a folding cat net [ACES FN-LXK Folding, Extendable 4' Net] in their vehicles. Folding cat nets make for relatively safe and effective capture of a loose stray or feral cat that is confined in a room. ACO personnel should also have a cat bag [Campbell Pet Company Cat Mesh Bags, 18x24] in their vehicle in order to remove a feral cat from a home built trap. (Note: ideally, ACOs should not attempt to transfer trapped cats from non-standard traps in the field see recommendation #14.)
7) RECOMMENDATION: Provide follow-up EBI training for already certified staff to correct technique and dose concerns.
FINDING: During my observation of EBI, I noted that placement of the needle for intraperitoneal injections was incorrect (left quadrant, 2-3 inches caudal to the umbilicus) rather than the GAIS injection site (midline 2-3 inches caudal to the umbilicus). I also noted less-than-label dosing of sodium pentobarbital which is unacceptable practice.
8) RECOMMENDATION: Provide Oster Power Pro cordless clipper or Oster Golden A-5 corded clipper and #40 blade [available at any grooming supply outlet] for EBI.
FINDING: The only clippers available to the EBI staff were old, pet-quality dog grooming clippers. The clippers were too dull to cut hair! As a result EBI staff were unable to shave the fur over the vein (GAIS) and had to guess at the exact vein location resulting in missed veins and multiple attempts.
Important: Implement as soon as time and resources allow (no rank order)
9) RECOMMENDATION: Eliminate mid-shift ACO truck unloading.
FINDING: GAIS is for ACOs to stay in their districts for their entire shift or until necessary to return to the shelter due to an injured animal or full load. ACS mid-shift unload procedure is in part dictated by vehicle design and extreme hot/cold weather concerns. Refer to recommendation #16 regarding vehicles.
10) RECOMMENDATION: Change policy prohibiting ACO field lunches.
FINDING: A barrier to ACOs remaining in the field throughout their shift is the ACS policy prohibiting them to take lunch in their districts. GAIS permits field personnel to request "Code 7" (lunch break). This permits them to stay in their district and not lose time traveling to and from ACS.
11) RECOMMENDATION: Change adoption hours to allow cleaning of kennels prior to public access; suggest hours that will accommodate the public being able to come in after work (noon-7PM) Note: current receiving hours are appropriate.
FINDING: ACS adoption hours are Monday through Saturday 10-5. Opening at 10 am puts undue pressure on kennel staff to complete their cleaning. GAIS recommends visitor hours that allow for the kennel areas to be completely clean and dry prior to opening to the public.
12) RECOMMENDATION: Provide bite sticks for officers, provide training/certification.
FINDING: Animal Care Officers do not have proper self defense equipment. As a result, they are not properly equipped to fend off an attack by a dog. Their only defensive tool is their snare pole and this is not what this piece of equipment is designed or suited for. ACOs should be provided with telescoping bite sticks [ACES: BS-E Extendable Bite Stick 26].
13) RECOMMENDATION: Consider changing to a 10-hour, 4-day work week for ACO and kennel attendant personnel. .
FINDING: It is typical for full service, large-city Animal Care and Control departments to operate on a 2-shift schedule of four, 10-hour days. Typically shift one runs Sunday though Wednesday and shift two runs Wednesday through Saturday. Wednesdays are double-up days and can be used for in-service training, intensive cleaning, "loose dog" special response teams8 and comp time off. Officers and kennel attendants can still be scheduled for early, mid and late shifts within the 4-10 work day structure.
14) RECOMMENDATION: Fill temporary kennel attendant slots with permanent employees.
FINDING: As explained to me, approximately half of the kennel attendant personnel are temporary (6-month maximum) employees. As a result, the kennel attendant workers are under-trained and unmotivated to excel as they know they will be "gone" in six months. The positions should be filled with permanent employees to provide for a stable and well-trained workforce. Reducing turnover will result in monetary savings and increased productivity.
15) RECOMMENDATION: Provide Tru-catch "mating" trap/carrier system (see recommendation #6) for ACS rental and implement agency trap rental policy requiring certain traps only for field transfer; other traps will be transported either by citizen or ACO (as vehicle space allows).
FINDING: As a result of non-uniform cat trap sizes and types, ACOs are frequently faced with the nearly-impossible and often dangerous field transfer of trapped feral cats and raccoons. GAIS is for an animal care and control agency to require certain trap types and sizes if the citizen wants to use their personal traps and have the department transfer animals in the field. Trying to transfer a feral cat or raccoon out of a non-standard trap and into a carrier is dangerous and frequently results in animals escaping. If a citizen wants to use their own (non-standard) trap then the ACO will transport the trap with the animal (if room is available on the vehicle) to ACS for citizen retrieval at a later time.
16) RECOMMENDATION: Eliminate flat bed trucks, replace with chassis mount or van conversion.
FINDING: ACS is currently equipped with animal control vehicles at both ends of the technological continuum. The four Mavron van conversion units are state of the art while the flat bed, open cage units are vintage 50's and 60's.
The problems associated with the flat bed units are numerous: 1) too high off the ground presenting lifting difficulties; 2) unprotected from the elements no air conditioning or heating; 3) animals are unshielded from one another; 4) loading and unloading is dangerous and difficult, often necessitating the use of snare poles 5) these units are unprofessional in appearance.
In order to load a 60 pound dog onto the flat bed the dog must be lifted approximately 4.5 feet off the ground. This is possible only if the dog is friendly and easily handled. If the dog is dangerous or nervous, the lift becomes unsafe, often necessitating a choke-fly lift with the snare pole. Choke-fly lifting a dog with a snare pole is inappropriate and dangerous for all concerned and presents a horrible public image it is also unacceptable practice.
There is no perfect solution to loading a dangerous or nervous dog into an animal control unit. Animal care and control departments have been struggling with this dilemma for decades. (Author note: as animal care supervisor at Multnomah County Animal Control in Portland, Oregon in the late 70's and as executive director of the Santa Cruz, California SPCA in the 80's I struggled with this same issue.) While there is no perfect solution it is clear that the ACS flat bed units present far more problems than solutions. Other options are readily available including van conversions (4 such units are already in use at ACS), chassis mounts, and slip-in units (see ACES [www.animal-care.com], Swab Wagon Company [www.swabwagon.com] and Mavron Animal Transport [www.mavron.com]).
17) RECOMMENDATION: Provide communication devices for ACOs (handheld radios and/or cell phones) and kennel attendants (pagers or small 2-way radios).
FINDING: Once out of their vehicles, ACOs are out of radio communication with ACS dispatch and in danger. GAIS provides officers with handheld radios and (often) cell phones. Kennel attendants are also out of communication and in danger. Small 2-way, pocket-sized radios are available.
18) RECOMMENDATION: Provide biocontainment clothing for use in parasite-infested environments.
FINDING: Inexpensive (under $10 each) biocontainment clothing is available from companies such as Magid Glove & Safety Company [www.magidglove.com].
1 Two examples or organizational inefficiency:
1) Bringing all field officers into the shelter to unload and have lunch is an example of inefficiency. Doing so results in approximately 14 hours of lost productivity (see footnote 2); the equivalent of two field officer positions each day.
2) Tagging feral cats is an example of nonsensical procedure. Each feral cat is required to have a string and red ID tag placed around his or her neck. Doing so results in lost time, is an unsafe work practice and necessitates inhumane handling of the feral cat. Also it simply isn't necessary to tag feral cats as nothing useful is gained by having the tag on the cat.
2 Non nonsensical field operations results in lost productivity of 14 hours per day. This is based on fourteen ACOs traveling from their district to the shelter at 11:15 AM to unload and clean. Travel, waiting in line to unload, unloading and truck cleanup -- then traveling back to the district is all time lost. Lost time is time unavailable to answer calls in the district. Actual lost time varied from officer to officer depending on the location of their district. An average of approximately 1 hour lost per officer is reasonable.
A further note about lost productivity: it is reasonable to calculate that 2 FTE ACO positions are lost due to mid shift unloading. That money could be used to improve field services or diverted into replacement of equipment.
3 Best Practices AHA Operational Guide EBI © 2005 (author: DK Fakkema)
Best, Acceptable and Unacceptable Practice Standards for EBI
> Best Practice is the application of state-of-the-art techniques and methodologies to the job at hand. Best Practice typically exceeds generally accepted industry standards. What is currently considered Best Practice can degrade to Acceptable Practice as new techniques, methodologies and public or industry values come into being.
> Acceptable Practice is the application of techniques and methodologies that may not be the best available, but meet generally accepted industry standards [GAIS]. What is currently considered Acceptable Practice can become Unacceptable Practice as new techniques and methodologies are developed.
> Unacceptable Practice is the application of out-of-date or non-approved techniques or methodologies that are not held generally acceptable within the industry. What was once considered Acceptable Practice or even Best Practice can become Unacceptable Practice (even illegal) as industry standards or public values change.
It is the responsibility of the professional in charge to keep current with changing industry standards and make changes where warranted. At an animal care and sheltering agency, it is the responsibility of the staff veterinarian (where such position exists), veterinary technician, shelter director or kennel manager to assure that animals are being treated according to acceptable standards of practice and if not, to advocate on their behalf until such standards are met or exceeded.
4 An example of how not to make a change is the recent policy prohibiting the use of snare poles on cats. The idea is a good one; snare poles do not work well on cats and are clumsy and ineffective at best, inhumane at worst. Unfortunately, the policy was implemented without proper training or equipment. Bite gloves and "cat grabbers" were issued; neither piece of equipment meets GAIS. The result: several personnel were reportedly bit and it immediately became apparent to staff that the policy didn't make sense; another example say staff, of management making a change without thinking it through.
What should have been done: 1) provide animal care officers with cat carriers, cat bags and field nets, 2) provide kennel staff with feral cat "cage" nets, 3) eliminate the feral cat tagging requirement, 4) house feral cats in individual cages only and 5) provide training on how to properly use all the new equipment (training now done).
5 Karen Sheppard-Hill, DVM and Director, City of Huntsville Animal Care and Control, Huntsville, Alabama; Jennifer Fakkema, DVM and Medical Director, John Ancrum SPCA, Charleston, South Carolina (report author's wife)
6 ACS posted pre-euthanasia dose table:
DOGS / CATS
> 100 pounds
7 Pre-euthanasia mixture dosage according to GAIS (industry standard for the past 30 years most frequently called "PreMix"):
- 0.6 mL per 10 pounds of body weight
- intramuscular administration
- Note: the correct dose and weight chart for the 5:1 ketamine/xylazine mixture was ALSO posted in the EBI room but not being used
8 Special response teams are for intensive roundups in high loose dog or problem complaint areas. Typically officers double up in vehicles and two or more teams focus their efforts on a problem