The use of animals in the circus has been controversial since animal welfare groups have documented instances of animal cruelty during the training of performing animals. The Humane Society of the United States has documented multiple cases of abuse and neglect,[30] and cites several reasons for opposing the use of animals in circuses, including confining enclosures, lack of regular veterinary care, abusive training methods and lack of oversight by regulating bodies.[31] Animal trainers have argued that some criticism is not based in fact, including beliefs that animals are 'hurt' by being shouted at, that caging is cruel and common, and the harm caused by the use of whips, chains or training implements.[32]