Why zoological accrediting groups need a way for people to anonymously report violations

No accrediting group in the United States provides a way for staff and the public to anonymously report concerns.

More than six months have passed since the public release of a USDA inspection report for the Miami SeaQuarium indicating that bottlenose dolphins had been starved for months to incentivize compliant participation in guest programs.¹ The situation has caused waves in the zoological community, but there’s one question for which no adequate answer has been determined: how did this happen at an accredited facility? The SeaQuarium is accredited by the Alliance for Marine Mammal Parks and Aquariums and maintains a Humane Conservation certification from American Humane. In theory, oversight by those two bodies should have prevented this situation from ever occurring - or, at least, stopped it before it devolved into the situation documented by the USDA. Neither accrediting organization has made any public statement on the situation, so there’s no way to say for sure, but it’s plausible that they both were simply unaware of the diet cuts that had been implemented and the problems that resulted from them.  

This exemplifies a chronic issue in the American zoological industry: there are few, if any, ways to report problems at facilities to their accrediting bodies, and those that exist do not have appropriate safeguards in place to protect reporters. While accrediting bodies have publicly committed to policing the operations and conduct of member facilities, the structure of the reporting options available and the long-standing culture of unaddressed retaliatory behavior within the industry functionally disincentivizes reporting.

The current lack of anonymous reporting options and subsequent lack of commitment to protecting staff who raise concerns belies the branding that indicates accrediting organizations are invested in creating actual accountability for the facilities they oversee. If these entities are truly serious about wanting to ensure their member facilities continue to adhere to the required standards throughout the entire accreditation cycle, they must find a way to encourage and support anonymous reporting. 

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Accreditation and certification bodies for zoological institutions² market their programs as guarantees of the quality and ethos of a facility. While the inspection and re-accreditation process occurs on a multi-year cycle for all five of the major accrediting groups in the United States, member facilities are expected to maintain compliance with the requisite set of standards for the entire accreditation term. However, none of these entities utilize routine mid-cycle assessments to verify this continued compliance. Therefore, issues that emerge between inspections are only made known to accrediting bodies if complaints are filed, the problems go viral online, or something is covered by the mainstream media. 

A simple solution to this issue would be to encourage staff and the visiting public to report any concerns directly to the accrediting bodies, so that possible violations could be assessed and acted on expediently. Facilitating this type of reporting, however, does not appear to be an industry priority: as of April 2023, three of the five major zoological accrediting/certifying groups in the United States provide no clear way to report violations or concerns. Prior to the middle of 2020, none of those five groups provided public-facing reporting options at all.

• The Association of Zoos and Aquariums (AZA) has a “Report a Concern with Accredited Zoos or Aquariums?” page that appears to have been created as recently as June of 2021.³ The page states that concerns should be submitted to the Accreditation Department via hard copy or a provided email address. Anonymous reports are allowed, although AZA does not guarantee that they can protect the identities of those making reports⁴.

• The Global Federation of Animal Sanctuaries (GFAS) has a “Report a Concern” page created in 2020⁵ with an embedded contact form. It does not allow for anonymous submissions. Their site does not guarantee anonymity for individuals making reports, and only states that “to the extent possible, we will keep your identity and our interactions with the sanctuary on this matter confidential.”

• The Zoological Association of America (ZAA) does not appear to have any formal method for reporting concerns about their accredited facilities. There is no public-facing contact information for the accreditation committee, although there is an email address on the “Contact Us” page for general questions.

• The Alliance of Marine Mammal Parks and Aquariums (AMMPA) does not appear to have any formal method for reporting concerns about their accredited facilities. There is no public-facing contact information for the accreditation committee, although it is possible to find the name and workplace of the committee chair on the website. The only contact option for the organization appears to be through the embedded form on the “Contact Us” page. This form does not allow for anonymous submissions and does not provide a category of message for “concerns” or anything similar.⁶

• American Humane (which provides the Humane Conservation certification, rather than an accreditation) does not appear to have any formal method for reporting concerns for certified facilities. There is no public-facing contact information for anyone involved in the certification on the website, nor any information about who is involved in running the program. The only contact option for appears to be through the embedded contact form on the “Inquire” page. This form is specifically for entities interested in applying for the certification, and does not allow for anonymous submissions.

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Without a way for concerns to be raised beyond the management of an individual facility, unsafe practices and inhumane treatment of animals can continue unaddressed. Smaller issues may escalate into major incidents that not only impact welfare but endanger the lives of animals, guests, and staff. In addition to these concerns, however, there are also a myriad of other impacts on the industry when people have no way to raise concerns about the operations of zoological facilities.  Well-known examples are visitors taking to social media to express their negative experiences, or employees who have left the field asking advocacy groups for help holding facilities accountable for unaddressed issues.

The Public’s Experience

The general zoo-going public frequently sees things that concern them when visiting accredited facilities, but is unsure what to do about it. Given the ubiquity of accreditation-as-continued-compliance branding, many people assume that whatever is encountered in an accredited facility is acceptable according to the relevant standards, no matter how distressing. Many who think that something they saw is unacceptable feel that facilities or accrediting groups are unlikely to want to hear their feedback; those that do decide to take action rarely know where to raise their concerns in order for it to be constructive. Brand messaging does not communicate the existence of, or encourage the use of, the reporting pathways for the two organizations that have them. This results in situations where guests, faced with a situation where the industry has made engagement difficult, are most likely to express their concerns on social media. 

Staff Members’ Concerns

As counterintuitive as it may seem from an external perspective, if staff at zoological facilities want to make a report to the group that accredits their employer, they only have access to the same formal reporting options currently available to members of the public. The risk to staff for utilizing those options, however, is high enough as to almost always prevent such action. 

The US zoological industry’s culture actively discourages staff from speaking out publicly about animal welfare issues or other concerns at their facilities. Much of this stems from fears that public discourse about extant problems might bring activist scrutiny or negative media attention to the facility, but this behavior has created a culture of silence that currently permeates the entire sector. Retribution for publicly discussing issues or openly contradicting the preferred industry narrative is common, and the backlash against staff who take that risk often comes from both employers and professional colleagues. However, staff who choose to air issues publicly frequently do so because they feel they have exhausted any internal options for raising concerns. When accrediting groups do not provide reporting options for staff at their member facilities, or do not express an interest in hearing from and protecting employees who want to report concerns, staff who have run into obstacles addressing issues internally will often feel they have no way to incite change other than going public.  

The Benefits of Anonymous Reporting

The clear solution to the issue is for accrediting groups to create and promote reporting options that are not only public facing, but allow for and even encourage anonymous reporting. To truly ensure success, however, a further step must be taken: a new standard must be added that prohibits facilities from retaliating against staff for submitting reports, and consequences for retaliation in such a case must be added to the mandatory code of conduct / ethics requirements for accredited facilities. 

These additional actions are necessary because there is already a well-established concern about whether any of these organizations have the infrastructure and protocols in place to handle either formal or informal anonymous reports with the appropriate level of discretion. While AZA and GFAS have explicit anonymous reporting options, ZAA, AMMPA, and American Humane do not. In many cases, a truly anonymous report by a staff member may be implausible, which AZA and GFAS acknowledge. Zoological positions are highly specialized and departments are often somewhat isolated from each other, resulting in a limited number of people who would have knowledge of a specific issue. Accrediting groups must make sure that, even in instances where a reporter can be identified by their employer, protections are codified into the standards that heavily penalize any attempt at retaliation. 

By creating a public-facing system that allows visitors and community members to contribute to reporting, a much wider pool of potential witnesses to problems is created. Zoo guests may observe issues from both the public side of the zoo and behind-the-scenes area (such as from tours into staff areas, or on zoo / staff social media accounts). The opportunity for a wide range of individuals to report concerns will help obscure the identity of staff reporters, making it safer for them to contact accrediting bodies even when retaliation is feared. 

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Retaliation is Currently Not Prohibited

As of April 2023, four of the major zoological accrediting groups in the US do not prohibit retaliatory behavior in their mandatory standards or code of conduct / ethics guidelines for member facilities.

• AZA standards require facilities to have an internal animal welfare reporting process free of risk of retribution⁷, but do not address retribution in other cases, such as reporting concerns to the AZA accreditation committee; the 2023 standards⁸ and the required Code of Professional Ethics⁹ don’t contain the words “whistleblower”, “anonymous”, or “retaliation”.

• There is no information available regarding ZAA’s approach to or oversight of possible retaliatory behavior by facilities they certify. The 2023 ZAA standards¹⁰ and the member Code of Conduct¹¹ do not contain the words “whistleblower”, “anonymous”, or “retaliation”.

• There is no information available regarding AMMPA’s approach to or oversight of possible retaliatory behavior by facilities they accredit. The 2020 Standards and Guidelines¹² (the most recent available version), as well as their International Code of Best Practices, do not contain the words “whistleblower,” “anonymous”, or “retaliation.” AMMPA does not appear to have a Code of Conduct policy for individual members or member facilities.

• There is no information available regarding American Humane's approach to or oversight of possible retaliatory behavior by facilities they certify. Their standards are proprietary and no additional information on the topic is available on the Human Conservation website.¹³

In fact, the only major zoological accreditation group in the US that explicitly protects whistleblowers is GFAS:

• The GFAS 2019 operating standards¹⁴ (the most recent version available online) prohibit nondisclosure agreements that would prevent staff from raising concerns regarding animal welfare and many other topics covered by the standards.¹⁵ The GFAS board has also adopted a “whistleblower” policy “that protects personnel from retaliation from coming forward with information about illegal activities, or failure to comply with policies, within the organization. This policy is made available to all personnel.” As this policy is listed in the operational standards, it appears to apply to all accredited sanctuaries.

Risk of Ethics Violations when Reporting

Another issue that accrediting groups must address is the risk that it could be an ethics violation to report concerns. Two of the major zoological accrediting organizations, AZA and ZAA, have language in their member conduct documents which could be interpreted so that reporting a concern to an accrediting body or government agency - or especially discussing the concern publicly if no reporting option exists - could be treated as a violation. 

• AZA’s mandatory member Code of Professional Ethics states that “a member shall not engage in conduct that adversely affects, or is prejudicial to, the concepts and ideals of the AZA.” This code of conduct applies to all AZA members but does not apply to the employees of AZA-accredited facilities (unless they’ve signed an agreement to abide by it as part of joining an AZA program). 

• ZAA’s mandatory member Code of Conduct states that: 

  • “A member shall not disperse or broadcast or campaign about his or her negative personal opinion about another member(s) or about the ZAA in any public forum including but not limited to newspapers, magazines, radio, television, by mass mail or email broadcast and/or via the internet.”

  •  “A member shall not perform an action or have conduct that brings discredit or censure on the ZAA or cause undue hardship, disrepute or disgrace to the ZAA as an entity, to the ZAA membership in general or to any ZAA member.” 

  • “A member shall not divulge any confidential or sensitive information regarding the ZAA and/or its members in general or any specific member(s) to anyone.”

• ZAA’s Code of Conduct applies to all ZAA members, but does not appear to apply to the staff of ZAA accredited facilities. 

While these member behavior rules do not apply to all industry staff, these prohibitions serve to intimidate organization members who might speak out, and reinforce the level of risk associated with whistleblowing or reporting concerns about accredited facilities. Many more industry staff may be subject to these strictures than is readily apparent, as those participating in animal programs or professional development options within AZA may have agreed to adhere to their Code of Professional Ethics in order to do so. 

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Taken as a whole, the existing issues and prohibitive language paint a picture of an industry that has chosen to make it difficult for interested parties to keep them up-to-date on concerns that occur between inspections. Implementing a functional, public-facing reporting system that accepts anonymous reports should be a priority for all accrediting groups. 

The creation of additional and anonymous reporting options will have a myriad of positive impacts for both accredited facilities and accreditation bodies. While at the most basic it will ensure high levels of animal welfare, staff safety, and other crucial topics, encouraging reporting by staff and the public will have numerous other benefits. 

Having a dialogue with the public and staff where concerns can be raised facilitates accrediting groups serving their oversight function proactively, with better results for all parties involved. Accrediting groups can best support their member facilities by providing advice and resources when issues are brought to their attention before they become severe. By identifying and addressing concerns earlier, and helping facilities rectify them before they escalate, accrediting groups can ensure that their facilities continue to be in compliance with the standards through the cycle. This would shift the dynamic between the accrediting groups and their member facilities from one that is adversarial and punitive to one that is open and collaborative. 

Many regular zoo-goers value accreditation bodies’ endorsement of a facility and put their trust in that level of oversight - but most people who recognize and look for accreditations do not realize that mid-cycle inspections occur infrequently, much less that they are only initiated when the organization becomes aware of an issue. The potential exists for public trust to deteriorate rapidly if that information were to be circulated widely as part of an anti-industry campaign. Adding an easy, public-facing reporting opinion is a way for accrediting groups to demonstrate their commitment to ensuring continued compliance with their standards. While many facilities would likely prefer that problems stay in-house and not be brought to the attention to their accrediting body, zoological facilities also often message that they support the accreditation process for the accountability and quality it represents; for that reason, facilities should support the creation of reporting systems as a way of demonstrating increased credibility for both the accrediting body and all of its member facilities. 

Safety or welfare issues, negative media articles, facility investigations, and accrediting decisions permeate public awareness and linger far longer than the actual event. Such situations always raise questions about whether accrediting groups were aware of severe issues before they became public knowledge, and whether any action had been taken to rectify or prevent them. Accrediting groups come across to the general zoo-going public as removed and inscrutable, which reduces trust and confidence. At least three of the major accrediting groups seem to keep accreditation and investigation decisions proprietary, requiring that interested parties take the validity of their judgment and the extent of their rigor on faith. This is proving to be an ineffective public relations strategy in the current era, as people increasingly distrust authority and are used to having access to a constant stream of information from which to draw their own conclusions. With little to no transparency from industry leadership, the animal-welfare-inclined public is increasingly distrustful of accrediting bodies who withhold information and ask for credibility based on established trust when serious events occur. The paper trail created by accepting reports will allow accrediting groups to respond with more transparency when accusations of malfeasance or ignorance arise. Even if some aspects of the process - such as accreditation decisions or penalties - are still kept proprietary, being able to provide any additional information about a situation will be valuable for responding to media inquiries and critiques by advocacy groups. Indicating that an accrediting group has been made aware of a possible concern but did not identify a violation of their standards - or indicating that the group is currently working with a member facility to address a reported concern - will garner far more credibility than a refusal to comment on a situation at all. 

The submission of false reports is always a risk when a public reporting option exists. Zoological facilities may be concerned that disgruntled current or ex-employees, or members of advocacy groups, may attempt to use such reporting to advance an agenda or personal vendetta. While this is a possibility, such a system may actually prove beneficial in these instances. Accrediting groups should be able to quickly determine when reports are false, and large volumes of targeted or clearly biased reports against a facility may be indicative of upcoming protests or other public relations issues for the accrediting organization and its members. Having a record of receiving such reports, and the actions taken to confirm the veracity of the concerns they contain, will be worth the up-front cost of time and labor required to address them upon submission. 

Creating reporting options that allow contributions from the general public as well as anonymous staff members will facilitate increased awareness of concerns and allow both accrediting groups and their member facilities to increase the transparency of their communications during periods of high-stake public interest, further engendering trust with their communities, elected representatives, and the zoo-going public in general.  

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So, about those starved dolphins… 

As a result of the USDA inspection that documented the starvation practices at the Miami Seaquarium, the animal care supervisor responsible for the bottlenose dolphin diet cuts was removed from the facility - but rather than being fired as a result of his actions, he was simply transferred to another Florida park owned by the same parent company. However, this isn’t an issue that has gone unaddressed by accrediting groups for six months - that’s just the timeline on which the public found out about the issue. The damning USDA report is from a focused inspection in July of 2022¹⁶; according to the report, the actual diet cuts for those bottlenose dolphins began in March of 2022. It’s been over a calendar year since the facility chose to begin starving their dolphins into compliance. 

The lack of visible action - or even any public comment - during this timeframe from the two accrediting groups ostensibly overseeing the welfare of the animals at that park is concerning. Multiple violations of AMMPA’s standards can be noted in the text of the July 2022 report. No information is available about how the organization addresses issues during the accreditation term or what consequences may be enacted against facilities that violate their standards. American Humane does not have publicly available standards, but their webpage detailing the certification process states “observations of willful acts or signs of abuse will automatically result in failure of the [initial] audit” and that “If it is determined after an audit that an American Humane CertifiedTM institution has fallen out of compliance, that institution will be immediately suspended from the program.” This does not appear to have happened. Neither organization has responded to an email requesting information on if any investigation or action to address the incident was occurring. The Miami Seaquarium’s most recent USDA inspection report that’s available online was from January of 2023¹⁷, with no non-compliances identified by the inspector. 

1. MSQ (MS Leisure Company) USDA targeted inspection 7/6/2022

2. For the purposes of this document, the term “zoological institution” or “zoological facility” will be used to refer to all business establishments which care for captive wild and exotic animals. These facilities may or may not exhibit animals to the public.

3. The earliest record the Wayback Machine has for this page is June 11, 2021. Carbon Dating the Web estimates page creation at 2021-06-11 T22:53:26

4. "If you request to remain anonymous, we will honor that request and will not share your name or position with the institution in question during the course of our inquiry. However, please keep in mind that the facility may determine that information on its own, based on knowledge obtained that is beyond our control.”

5. The earliest record the Wayback Machine has for this page is August 12, 2022. Carbon Dating the Web estimates page creation at 2020-08-12 T00:35:53

6. Current categories as of January 2023 include: facility accreditation/membership, friends of the Alliance program, careers/internships, school project/education, scientific research, media, and other.

7. 1.5.8. The institution must develop and implement a clear and transparent process for identifying, communicating, and addressing animal welfare concerns from paid or unpaid staff within the institution in a timely manner, and without retribution.

8. https://assets.speakcdn.com/assets/2332/aza-accreditation-standards.pdfhttps://assets.speakcdn.com/assets/2332/aza-accreditation-standards.pdf

9. https://www.aza.org/code-of-ethics?locale=en

10. https://zaa.org/resources/Documents/Resources/ZAA%20Accreditation%20Standards_2023.pdf

11. The ZAA member Code of Conduct is not publicly available to non-members

12. https://www.ammpa.org/sites/default/files/files/Resource%20Library/AMMPA-StandardsAndGuidelines-Feb2020.pdf

13. American Humane certification deals with animal welfare rather than business practices, but it could be expected that part of the standards would prohibit retaliation against staff for raising welfare concerns.

14. GFAS operational standards

15. HR-2. GFAS recognizes a sanctuary has an interest and right to protect its intellectual property, proprietary information, trade secrets and financial information. Accordingly, a sanctuary may require its employees, volunteers, interns and others to sign a Non-Disclosure Agreement to protect this information. However, a sanctuary shall not require its employees, volunteers, interns or others to sign a Non-Disclosure Agreement to prevent disclosure of information or concerns about the care, safety, treatment, transportation, lack of resources and/or any information that directly relates to a sanctuary’s inability, or risk of inability, to properly provide care for animals in sanctuary residence.

16. MSQ (MS Leisure Company) USDA targeted inspection 7/6/2022

17. MSQ (MS Leisure Company) USDA routine inspection 1/19/2023