In entertainment, there’s an old adage that you never involve a dog unless you are okay being upstaged by it. It’s the same reason why the easiest way to establish a villain in a story is to have that character harm a dog. “Man’s Best Friend” isn’t just a marketing tagline; it’s a truism for anybody who’s ever owned a pooch. We project a lot of ourselves onto our dogs, but there really is a deep symbiosis between us and them that we share with very few other animals. So it makes sense that “A Dog’s Purpose,” a book about a dog reincarnated several times and its reflections on its different lives with different people, might be successful enough to make into a movie. And it makes sense that when you make a movie about dogs, you’re going to have a lot of dog actors. And when you have a lot of animal actors, you need to make sure they’re all taken care of properly.

Unfortunately, that doesn’t quite appear to have been the case with the movie adaptation of “A Dog’s Purpose,” scheduled for wide release on Friday, Jan. 27. Just a few days before, media outlet/gossipmonger TMZ published video that appeared to show one of the canine actors in the movie being forced into churning water to simulate a scene where a police dog jumps into a raging river. The dog clearly doesn’t want to go in, but the handler forces it to go in before pulling it out again, all while you can clearly hear other people in the set saying that the dog should just be thrown. A second bit of video shows the same dog, in a different shot, swimming in the water, but it goes under briefly, causing on-site divers to scramble and get it out. The upshot of the video is that the production of “A Dog’s Purpose” mistreated its canine actors. But it might not be as clear-cut as that. And the conclusions to draw might be a lot different than the ones we reflexively jump to upon seeing the video.

As you might expect, the TMZ video quickly went viral and caused such an uproar that Universal Pictures canceled the movie’s premiere, so as to avoid any opportunity for additional bad publicity. You know what you don’t want at your premiere? A bunch of angry animal rights activists. But the filmmakers have defended the film, saying the video was largely out of context and that the animal activity on set was monitored by the American Humane Association, whose “No Animals Were Harmed” program is the leading method by which Hollywood ensures that animals used in motion pictures are not mistreated. AHA CEO Robin Ganzert went even further, writing an op-ed that defends the making of “A Dog’s Purpose” and the validity of the “no Animals Were Harmed” certification. But that’s where things start to get a little shifty.

Ganzert writes that no dog was ever forced into the water against its will, even though in the video, we can clearly see the dog’s handler forcing it into the churning pool. Furthermore, Ganzert wrote that following the video’s release, the AHA launched an independent investigation into the AHA’s on-site monitoring of “A Dog’s Purpose” just to make sure everything is on the level. But the AHA is already an independent monitor in this situation. Why wouldn’t it already know what happened? Why wouldn’t it already have its own report to cite?

The reason, suggests “A Dog’s Life Producer” Gavin Polone, is that the AHA’s “No Animals Were Harmed” program is a bit of a hollow exercise. In his own defense of the film, he expresses regret in putting his faith in the AHA, which he has previously criticized (both here and here) as being less than a complete protection for acting animals, and for having a conflict of interest between its own certification program and the Hollywood productions that ultimately pay for it. He even goes so far as to suggest that the AHA should be replaced as the movie industry’s regulator of choice.

The reasons why are more deeply discussed in a 2013 investigative piece published by the Hollywood Reporter that alleges a long history of conflict of interest, poor follow-up, botched investigations, and rubber stamping that have rendered the AHA’s regulatory efforts all but worthless. This was the case on a number of productions, but especially of the set of “Luck,” the now-cancelled HBO series about horse racing, in which a number of horses died, the AHA’s oversight seemed to be at the mercy of the show’s producers more than the AHA itself, and nobody seemed to be held accountable for the animal deaths.

These are all serious criticisms to throw around, but one can imagine how they get started. A quick look at the AHA’s IRS 990 form notes that like a lot of non-profit organizations, the AHA really does make a profit after all, and is basically business operating under the auspices of inherently beneficial work. But “No Animals Were Harmed” is in fact a revenue stream for the AHA. Its services are paid for by the very productions it monitors, so when AHA staffers allege that the organization whitewashes its findings to make Hollywood happy, there arises a strong desire to start connecting dots.

The problem with voluntary, paid oversight services is always the threat of conflict of interest. It’s not impossible for there to be private oversight agencies doing a sterling job, but there needs to be transparency, deeply respected lines between church and state, an empowered speak-up culture, and a long track record not just of things going right, but of the proper corrective actions being taken when things go wrong. The problem with the AHA—if current reporting is indeed covering this fairly and accurately—is that there is a lack of transparency, there is financial motivation to compromise the integrity of monitoring, there is a history of poor oversight within the “No Animals Were Harmed” program, and there is a history of the AHA certification being a bit of a rubber stamp. All of these things are not hard to find. What is, is what the AHA intends to do about it.