Tag Archives: animal welfare act

USDA publishes 2015 Animal Research Statistics

Congratulations to the USDA/APHIS for getting ahead of the curve for a second time and making the US the first country to publish its 2015 animal research statistics. Overall, the number of animals (covered by the Animal Welfare Act) used in research fell 8% from 834,453 (2014) to 767,622 (2015).

These statistics do not include all animals as most mice, rats, and fish are not covered by the Animal Welfare Act – though they are still covered by other regulations that protect animal welfare. We also have not included the 136,525 animals which were kept in research facilities in 2015 but were not involved in any research studies.

USDA Statistics_2016_A

The statistics show that 53% of research is on guinea pigs, hamsters and rabbits, while 11% is on dogs or cats and 8% on non-human primates. In the UK, where mice, rats, fish and birds are counted in the annual statistics, over 97% of research is on rodents, birds and fish. Across the EU, which measures animal use slightly differently, 93% of research is on species not counted under the Animal Welfare Act (AWA). If similar proportions were applied the US, the total number of vertebrates used in research in the US would be between 11 and 25 million, however there are no statistics to confirm this.

USDA Statistics_2016_B

If we look at the changes between the 2014 and 2015 statistics we can see a drop in the number of studies in hamsters, rabbits, cats and the “all other animals” category. Notably, there was a 7.3% rise in the number of non-human primates used although this comes the year after a 9.9% fall in their numbers.

USDA Statistics_2016_C

There has been a downward trend in the number of AWA-covered animals used in the last three decades, with a 64% drop in numbers between 1985 and 2015. It is also likely that, similar to the UK, a move towards using more genetically altered mice and fish has reduced the numbers of other AWA-covered species of animals used. In the UK this change in the species of animals studied has contributed to an overall increase in the numbers of animals used in research in the past 15 years.

Rises and falls in the number of animals used reflects many factors including the level of biomedical activity in a country, trending areas of research, changes to legislations at home and abroad, outsourcing research to and from other countries, and new technologies (which may either replace animal studies or create reasons for new animal experiments).

It is important to note that the number of animals cannot be tallied across years to get an accurate measure of total number of animals. This is because animals in longitudinal studies are counted each year. Thus, if the same 10 animals are in a research facility for 10 years, they would appear in the stats of each year – adding these numbers would incorrectly create the illusion of 100 animals being used.

Speaking of Research welcomes the open publication of these animal research statistics as offering the public a clear idea of what animal research goes on in their country.

When are rats, mice, birds and fish protected by US federal laws?

There is sometimes confusion about how US law protects rats, mice and non-mammalian vertebrates such as birds and fish. Much of this confusion is rooted in the fact that the US Animal Welfare Act (AWA) explicitly excludes purpose-bred rodents (rats of the genus Rattus rattus, mice of the genus Mus mus), as well as birds that were specifically bred for research. Research with these purpose-bred rats and mice likely comprises the overwhelming majority of vertebrate animals in research in the US, but it is not overseen by the United States Department of Agriculture (USDA).

Sometimes this fact is used mistakenly (or perhaps purposely?) to suggest that all species not covered by the Animal Welfare Act are not protected by any federal laws.

Claims that research with non-AWA-covered species is not subject to care standards, external oversight, and public transparency are demonstrably untrue.

This post aims to address these misconceptions by looking at when and how rats, mice, and birds in research are covered by federal laws.

Mouse Science

Image from Understanding Animal Research

In the US, both the USDA, through the Animal and Plant Health Inspection Service (APHIS), and the Department of Health and Human Services (DHHS), through the Public Health Service (PHS) and National Institutes of Health (NIH) Office of Laboratory Animal Welfare (OLAW), are responsible for the oversight animal research. The table below provides a broad overview of the federal regulation and oversight agencies for different species and types of research.

Covered species are defined as: "with certain exceptions, any live or dead dog, cat, monkey (nonhuman primate mammal), guinea pig, hamster, rabbit, or such other warm-blooded animal, as the Secretary [of Agriculture] may determine is being used, or is intended for use for research”

Overview of animal research regulation in the US. The Animal Welfare Act (AWA) states that covered species are defined as: “with certain exceptions, any live or dead dog, cat, monkey (nonhuman primate mammal), guinea pig, hamster, rabbit, or such other warm-blooded animal, as the Secretary [of Agriculture] may determine is being used, or is intended for use for research” (7 U.S.C. 2132(g) The 2002 Farm Bill amended this definition to exclude purpose-bred rats, mice, and birds from the provisions of the AWA. Note that certain types of research with animals and most animal testing are also subject to regulation and oversight by the US Food and Drug Administration (FDA).

Animal Welfare Act (AWA) and USDA. The USDA is charged with enforcement of the AWA. The AWA applies to research with a range of species that includes: “with certain exceptions, any live or dead dog, cat, monkey (nonhuman primate mammal), guinea pig, hamster, rabbit, or such other warm-blooded animal, as the Secretary [of Agriculture] may determine is being used, or is intended for use for research” (7 U.S.C. 2132(g), referred to here as “USDA-covered species.” Institutions that engage in research with covered species must be registered with the USDA.  The AWA also applies to zoos, entertainment facilities, breeders, and other facilities that engage covered species in activities that involve public contact. All such facilities must be licensed by the USDA and research may also be conducted in facilities licensed for non-research purposes.

An amendment to the 2002 Farm Bill  specifically excluded from AWA oversight rats of the genus Rattus rattus, mice of the genus Mus mus, and birds specifically bred for research. Thus, research with these rats, mice, and birds, which likely comprises the overwhelming majority of vertebrate animals in research in the US, is not overseen by the USDA.

Does that mean rats, mice, and birds are not covered by federal animal welfare laws?

It depends on the funding! In fact, many rats, mice, and birds bred for research are covered by federal law.

Why?  Because, for federally-funded research, another federal regulation specifies the conditions for animal care, animal research, external oversight, and associated public transparency via a second federal agency. This includes, for example, university research funded by the National Institutes of Health, the National Science Foundation, or other federal agencies.

PHS and OLAW. The Health Research Extension Act (HREA; 1985) provides the statutory authority for the PHS Policy on Humane Care and Use of Laboratory Animals (PHS Policy), which applies to all PHS-funded research with live vertebrate animals.  In brief, such research must follow the National Research Council’s Guide for the Care and Use of Animals in Research (The Guide) (NRC, 2011).  Each institution receiving PHS funding for research with vertebrate animals is required to have an Assurance of Compliance (Assurance) with OLAW. The Assurance describes policies and procedures adopted by the institution in order to comply with PHS Policy.

The NIH website provides extensive information about PHS policy and OLAW.


Guide for the Care and Use of Laboratory Animals

Guide for the Care and Use of Laboratory Animals

Food and Drug Administration (FDA). Certain types of research with animals and most animal testing are also subject to oversight and regulation by the US FDA.

Part of the federal regulation governing animal research also requires that each institution engaged in research has a mechanism for ethical consideration, approval, oversight and monitoring of animal care and research. Thus, there are also oversight bodies at each institution that are charged with the approval, monitoring, and reporting of activities with animals.

Institutional Animal Care and Use Committees (IACUC). Animal research oversight at the institutional level is entrusted to an Institutional Animal Care and Use Committee or “IACUC.” The responsibilities of the IACUC are spelled out in the AWA regulations and the PHS policy. Read more about IACUC here: http://grants.nih.gov/grants/olaw/tutorial/iacuc.htm

What about rats, mice, and birds that are not in federally-funded research?

While privately-funded research is not subject to the AWA or PHS Policy, there are other mechanisms that are used to ensure standards of animal care and research review, such as voluntary accreditation of the institutions’ animal care program. Such research may also fall under FDA oversight and, as such, be required to follow PHS Policy.

Private accreditation.  An institution may choose to seek and maintain voluntary accreditation by a private agency, AAALAC, International (AAALAC). In the US, AAALAC accreditation depends on demonstrating compliance with the The Guide; thus, institutions that are not overseen by APHIS or OLAW may choose to be accredited and adopt the same standards for the care and treatment of research animals. Private accreditation for the care of captive animals is common across different kinds of facilities that house nonhuman animals, including those in research, but also in zoos and sanctuaries, who have their own accreditation organizations (e.g., American Zoological Association, AZA; Global Federation of Animal Sanctuaries, GFAS). Importantly, however, unlike oversight by a federal entity, voluntary accreditation does not provide a venue for public oversight and enforcement, nor does it allow for public transparency. For example, both USDA’s APHIS and PHS’s OLAW are responsive to public requests for investigation of facilities and records relating to oversight of those facilities. Private accreditation agencies do not provide public transparency of the accreditation process and/or inspection reports.

In Conclusion:

There are many sources of federal and local protection of animals in laboratories. Any research on AWA-covered species OR research that receives federal funding will be covered by federal laws aimed at ensuring laboratory animal welfare. Those laws provide for external oversight and for public transparency of records including, for example, inspection and investigation reports.

Most research is also covered by the IACUC system, which provides for oversight and, for many public institutions, another route of public transparency via state open records. Finally, many facilities– both public and private– maintain voluntary accreditation, which also should have a positive impact on animal welfare.

Speaking of Research

For more information about regulation, also see:

Update 5/24/16:  “New MOU Among NIH, USDA, and FDA.  NIH, USDA, and FDA have participated under a Memorandum of Understanding (MOU) Concerning Laboratory Animal Welfare for over 30 years. Each agency, operating under its own authority, has specific responsibilities for fostering proper animal care and welfare. This agreement sets forth a framework for reciprocal cooperation intended to enhance agency effectiveness while avoiding duplication of efforts in achieving required standards for the care and use of laboratory animals. The new MOU is available at: http://grants.nih.gov/grants/olaw/references/finalmou.htm.”


Animal research successes spur growth in science…but PeTA can only complain

What do multiple myeloma, influenza, advanced breast cancer, atrial fibrillation, thyroid cancer, ear infection, advanced ovarian cancer and obesity all have in common? One commonality is obvious – they cause suffering, sickness and sometimes death in people around the world. Another commonality is less obvious – these are each conditions that are now being treated with new drugs just approved by the U.S. Food and Drug Administration (FDA) in the past three months alone. That’s right… in the period from Thanksgiving 2014 until now, new drugs that treat each of these conditions have become available, and these agents will be used to treat the illnesses that may affect millions of Americans. Eventually, they will likely have enormous worldwide impacts on these diseases. That’s something to be thankful for.

While some are thankful that the scientific progress is successfully tackling human suffering and disease, others cast doubt on the way that progress is achieved. In a newly published analysis entitled “Trends in animal use at US research facilities” [1], employees of People for the Ethical Treatment of Animals (PeTA) – a self-avowed animal rights organization – report that, amongst the largest research universities in the United States, the number of animals involved in research has grown by over 70% during the past 15 years. In their publication, the authors express alarm over the growing use of animals not covered by the Animal Welfare Act (AWA), mostly mice and fish, in biomedical research, without making any mention of the impact of this research growth.

This growth in animal research in the US is directly linked to an accelerating pace of scientific study and its benefits. A brief visit to the FDA’s “New Drugs at FDA page” makes it quickly apparent that the rate of approval of new medications is astounding. Where is this progress coming from? At least in part, it’s coming from the scientific discoveries that are pouring out of the research laboratories located in colleges and universities, institutes and pharmaceutical and biotechnology companies around the globe. A good example is the innovative BiTE antibody Blincyto (blinatumomab) which was approved for use in treating B-cell acute lymphoblastic leukemia in December 2014 (clinical evaluation against other cancers is ongoing); as we discussed in a blog post in 2008, animal research – particularly studies in mice – played a key role in its development and early evaluation.

Thanks to the researchers that occupy laboratories around the world, scientific discoveries are coming faster than ever, and all of us benefit. It’s not just that there is more research being done – it’s that the impact of the science is better than ever thanks to more advanced technologies, accumulating knowledge of how the body works and more advanced animals models, including ones that mimic human disease processes in increasingly sophisticated ways that promote new discoveries and new opportunities to develop novel drugs.

Why is the scale of animal research growing in the US? The answer is clear: scientific progress is cumulative. One discovery often enables multiple other lines of work. The discovery of the structure of DNA, for example, enabled thousands of efforts to find the genetic causes of disease. Because of this, successes build on successes and research grows.

What is the consequence of the growth in animal research? The answer is: new treatments, new cures, less sickness and longer, healthier lives.

In their paper, the PeTA employees fail to mention any of the following accomplishments, allow of which resulted from the growing scientific research efforts around the world:

But this isn’t the end. To these existing accomplishments, add the work that was started in the past 15 years and will yet unfold in the forthcoming decade AND the overwhelming progress in basic/fundamental research that will lead to new treatments and cures throughout the first half of the 21st century, and you have the recipe for a growing animal research infrastructure in this country.

As recent statistics from the UK indicate, the increase in the use of mice and fish in research is driven almost entirely by the increasing number of studies that involve the use of genetically-modified (GM) animals. In other words, the increase is driven by scientific and technological advances that had a profound impact on biomedical research over the past 15 years, rather than any desire to avoid using species regulated by the AWA (while mice and fish studied in Universities are not covered by the AWA, research involving them is regulated in multiple ways, including through the federal Office of Laboratory Animal Welfare which issues the PHS Guide for the Care and Use of Laboratory Animals).

“Recent statistics from the UK indicate, the increase in the use of mice and fish in research is driven almost entirely by the increasing number of studies that involve the use of genetically-modified (GM) animals.”

Growing study of GM animals has occurred because these models are enormously useful. To take just one example, the National Institute of Child Health and Development recently published an online article entitled “It’s in the DNA: Animal Models Offer Clues to Human Development”, discussing the role of animal models in helping to understand human development and developmental disorders. But this is far from the only example, studies in GM mice are key to many of the state-of-the-art emerging fields in biomedical research. These range from the very new areas of optogenetics – which uses light to control activation of individual cells – and gene editing techniques such as CRISPR that have the potential to cure genetic disorders, to new therapies such as cancer immunotherapy and treatments for rare genetic disorders such as progeria and Pompe disease which are being used to successfully treat patients for whom effective therapies were previously unavailable.

The rise in the numbers of zebra fish is also driven by their value as research models. As vertebrates they share over 84% of the genes that cause disease when defective in humans, while their rapid reproduction and transparent eggs make them ideal subjects for genetic and developmental studies. It’s not surprising that they are both an increasingly popular species in basic biomedical research, and in the preclinical evaluation of potential new therapies and of the environmental safety of chemicals.

In recent years zebra fish have become an increasingly popular species in biomedical research.

What the statistics presented by PeTA in their article don’t tell you is that, while the number of experiments and studies have increased, animal research increasingly involves Refined techniques that produce minimized harm to the subjects and Reduced numbers of animals per study. And of course, animal research directly led to the ability to Replace animals in some types of studies, altogether. The efficacy and efficiency of animal research is advancing, and individual discoveries are, on average, being made with fewer animals. That is a fact missed entirely by the PeTA article.

Furthermore, within the concept of refinement is the idea that researchers should use animals that will suffer less in a laboratory setting wherever possible [2]. So replacing a small number of “higher” mammals with a high number of “lower” animals is consistent with the 3Rs principles of animal welfare. PeTA neglect to mention that USDA statistics show a 40% fall in the use of AWA-covered species over the last 15 years, and it is likely that a small proportion of the rise in use of non-AWA covered species is due to technological advances that have allowed non-AWA species (e.g. GM mice) to replace AWA species (e.g. monkeys) in some studies, for example to develop new treatments for HIV/AIDS, in line with the principle of Refinement we have outlined.

Number of animals used annually for research in the US

“PeTA neglect to mention that USDA statistics show a 40% fall in the use of AWA-covered species over the last 15 years”

Through the implementation of these 3Rs, scientists ensure that they engage in socially-responsible and ethical work. What the authors of the PeTA study should do is to explain how achieving their end goal of a virtual end to animal research, which will reverse the trend of accelerating discovery and medical progress upon which it depends, is ethical or defensible.

  1. Goodman, J., Chandna A., and Roe K. 2015. Trends in animal use at US research facilities in: J Med Ethics. 0:1-3
  2. Richmond, J., 2014. Refinement Alternatives: Minimizing Pain and Distress in Allen, D. and Waters M. ed. In Vivo Toxicity Testing” in: Reducing, Refining and Replacing the Use of Animals in Toxicity Testing. Cambridge: RSC. pp. 133

David Jentsch

USDA Statistics for Animals Used in Research in 2012

In 2011 the USDA stopped publishing its animal research statistics on the Animal and Plant Health Inspection Service (APHIS) website (with the last full stats being 2010). We have recently received the 2012 statistics for animals used in research under the Animal Welfare Act. Overall the number of animals used in research fell by 16% since 2010, falling over 180,000  from over 1.1 million (2010) to just over 950,000 (2012).

Click to Enlarge

Click to Enlarge

These statistics do not include all animals as most mice, rats, and fish are not covered by the Animal Welfare Act – though they are still covered by other regulations that protect animal welfare.

We can see that rodents (guinea pigs, hamsters and other rodents) and rabbits together account for 67.3% of all research animals, with cats, dogs and primates accounting for 16% of research. In the UK, where mice, rats, fish and birds are counted in the annual statistics, over 98% of research is on rodents, birds and fish. Across the EU, which measures animal use slightly differently, 93% of research is on species not counted under the Animal Welfare Act. We would expect similar patterns to be true in the US – although there are no statistics to confirm this.

Click to Enlarge

Click to Enlarge

If we look at the changes between the 2010 and 2012 statistics we can see a drop in the number of animals of most species between 2010 and 2012, with only pigs and cats going against the trend. Most notably the number of non-human primates has fallen by 9.5%, with an even larger drop in the number of rabbits (11.1% drop).

Animals used in research 2010 vs 2012

It is unclear whether the 16% drop represents a clear downward trend for the numbers of animals used in research, or is simply annual variability, though it would fit in a general downward trend in the US statistics since the mid 1980s. It is also likely that, similar to the UK, a move towards using more genetically altered mice has reduce the numbers of other animals used (those counted by the USDA under the Animal Welfare Act).

Speaking of Research

New UK Animal Research Law is a Victory for Animals and Scientists

As the science correspondent of a top UK newspaper said to me earlier this year “Call me cynical, but there are very few things that kill a story quite like having “EU Directive” in the title.”

He was referring of course to the snappily-titled “Directive 2010/63/EU of the European Parliament and of the Council of 22 September 2010 on the Protection of Animals Used for Scientific Purposes” which was transposed into UK law in December 2012. This is how the various EU countries are doing as regards implementation:

Adapted from the excellent http://animaltestingperspectives.org/transposition

Adapted from the excellent http://animaltestingperspectives.org/transposition (Click to enlarge)

In December 2012, the UK’s House of Commons Statutory Instruments committee unanimously approved the amendments to the Animals (Scientific Procedures) Act, 1986 which harmonised UK laws on animal research with the new EU Directive 2010/63. All that remains is for the Home Office to develop supplementary guidance which will clarify specific aspects of the regulations.

The changes, as far as UK science is concerned, are minimal partly because the UK was allowed to keep its standards where they were higher, for instance granting special protection to dogs, cats, primates and equidae. We continue to have a similarly equipped inspectorate, and it appears we will have a similar ethical review process, but these are the sort of details currently being hammered out in the post-legislation guidance.

Another reason for this similarity is the fact the UK has been at the forefront of developing the new legislation, bringing the rest of Europe up to the UK’s standards of animal welfare, whilst harmonising legislative differences and dispensing with some of the red tape that had built up over 30 years that wasted time without improving animal welfare.

Some animal rights and abolitionist organisations continue to fret that regulations will somehow be substantially reduced as the guidance is developed over the next several months but if anything the risks run the other way, with unnecessary red tape in the form of data duplication, or the inclusion of details that benefit only campaigning groups which thrive on the misrepresentation of biological research.

There is also a rather flippant suggestion that project licences should be published, with personal or commercial information redacted, which appears to misunderstand the fact that the triangulation even of redacted information with published materials and the known specialisms of different researchers or research facilities make identifying individuals a moment’s work.

This has serious security, legal and commercial ramifications for some researchers and the institutions charged with protecting their health and safety. That said, it should be possible to release more information to the public in the future, if the project licenses are correctly designed and the ground rules set in a certain way, but once again it is researchers, not campaigning groups, leading the way in finding a practicable solution.

This approach is also in line with the Declaration of Openness signed by over forty leading research institutions and funders. Openness is something UK scientists hope will help to reassure the public, as they may come to see the true costs and the true benefits of research for themselves, not through the distorting filter of campaigning groups.

Nevertheless, the de facto changes to UK regulation of animal research are small – the UK has a system, it certainly works well for animals and it should remain so. The Directive is an important step in bringing many European countries towards the high laboratory animal welfare standards that exist in the UK. Although the Directive does not match the UK’s strict animal welfare laws in every area, the UK will retain its higher standards in all areas where they exist.

Moreover, in many cases scientists have objectives in common with animal welfare groups. Scientists want a well-financed inspectorate: they speed up project approvals and help with legal compliance. Scientists want clean, happy animals: they make better test subjects, and the meme of the “mad scientist” torturing animals is, after all, the construction of a fevered imagination – a foul-tasting cocktail of H.G. Wells, Frankenstein and internet footage of rare and atypical abuses.

Of course, anti-research groups will still push to gain more influence over the ethical review process, such as via Animal Welfare and Ethical Review Bodies (AWERBs), which will preview project licenses, as happens now, at a local level. Abolitionists want to sit on these boards so they can more easily dig up campaigning material and have started describing the current system as a “cosy box ticking exercise” or similar, as usual implying a dark conspiracy where there is none in order to wangle a seat at the table, despite lacking credibility, understanding or perspective.

They may be disappointed; however, since another change taking place from 2014 will be the retrospective assessment of suffering. For years, project licence holders have overestimated the suffering an experiment may engender in order to avoid accidentally exceeding the terms of their project licence. The abolitionists have then dined out on the millions of examples of suffering they think they’ve identified, when in fact they have once again misunderstood what they are reading. From 2014 onwards however they might just find themselves having to vet three and a half million procedures that are no more severe than temporary discomfort or a blood draw: hardly the grim picture of torture suggested by their literature.

Speaking of Research will continue to keep you updated on developments to the EU Directive and its implementation across Europe.

Speaking of Research

An Open Letter to the Laboratory Animal Veterinary Community and Research Institution Administration

The decades following passage of the U.S. Animal Welfare Act in the 1960s are marked with wide-ranging and significant changes to the administration, oversight, and responsibility for daily operations of institutions engaged in laboratory animal research. The intent of the legislation, and the central purpose of the accompanying and continuing changes, is to best ensure the welfare of animals in research.

This goal encompasses all aspects of laboratory animal care— their participation in ethical scientific studies, their humane treatment during daily care and maintenance, and their receipt of the highest standard of clinical care. Do scientists engaged in animal research perform all of these duties?  No. In fact, by law, it is not scientists who have the ultimate responsibility for oversight of all issues involved in animal welfare, but the attending veterinarian and institutional officials.

In practice, there are a range of individuals who share in the responsibility to provide for animal welfare. Many different types of expertise are needed to provide the best management of a laboratory animal research facility. Scientists working with animals have expertise in the topic their research addresses, in the activities that research requires, and in use of animals in research. Depending on their research area, background, and training they may have tremendous depth and breadth of knowledge about the animals’ behavior, psychology, physiology, and other systems. But it takes more than this to accomplish all that is needed to maintain an animal research program.

Animal research programs always include veterinary staff to provide the animals with clinical care. They typically also include animal care staff to provide daily husbandry; behavioral management staff to provide environmental enrichment and animal training; and facility management staff who work with engineers and others to maintain clean and safe environments for the animals. In addition to facility management, clinical care, and daily husbandry there are also divisions of personnel charged with evaluation and oversight of the research, including the Institutional Animal Care and Use Committee, associated staff, and compliance officers. Oversight for the entirety of the animal research program typically rests at the level of university administration.

In sum, the number of individuals and divisions now involved in ensuring laboratory animals’ welfare and humane treatment in ethical scientific studies extends far beyond the scientists most identified with animal research.  What does this mean? It means that there is a great deal of shared responsibility for both successes and the occasional failures in the conduct of laboratory animal science.  It also means that any discussion of continued improvements in the daily activities that affect animal welfare, as well as changes in policies that govern the conduct of animal research, should benefit from teamwork among these different stakeholders.

A Veterinary Technician works with rodents

A huge number of people are involved in animal welfare in laboratories

Finally, it should mean that in public dialogue the voices of scientists and research advocates are routinely joined by laboratory animal veterinarians, university officials, and others who play important roles in laboratory animal research.  This is true even when that research is controversial and has the potential to elicit attention from animal rights activists. All too often, however, few of these voices are raised when the public eye is turned to issues of concern in animal facilities. Rather, in place of thoughtful answers to questions raised by a range of parties—by the press, by animal rights activists, by other scientists, by USDA reports— what is often offered are generic statements that contribute little to understanding of the events and the context in which they occurred. For example, in response to virtually any type of incident, an institution’s response might be along the lines of:  “We follow all regulations and hold animal welfare in highest regard and priority…”

It is long past the time that our community should have abandoned this approach and required more from each of its members and divisions.  To accept anything less is a mistake.  Absence of accurate information, accompanied by the failure of institutions and their representatives to engage in public dialogue, only further erodes public trust.

The intent of the AWA, subsequent legislation and policies, accreditation programs, revisions of guidelines, and continued increases in regulatory oversight is to ensure the best animal welfare and humane treatment possible.  In the rare cases where the apparatuses put in place to achieve this goal fail, sometimes from accident or human error, two things must happen.  First, it is contingent upon all of those involved to immediately work together to identify the reason for the failure and ways to minimize the possibility that it occurs again.  Second, those ultimately responsible for oversight should provide the public with accurate information, explanation, and opportunity for discussion.  At the very least, they should be able to articulate the rationale and their support for the research programs and their contribution to scientific and medical progress.

Are we suggesting that attending veterinarians and institutional officials open their doors for daily chats with animal rights activists?  No, but we do believe that addressing legitimate public concerns and questions about their animal research programs are among the key obligations of those charged with oversight and conduct of those programs.

While scientists can address questions about the scientific side of animal research, we need the laboratory animal care and veterinary staff to provide their expertise in service of addressing public questions about clinical care and husbandry.  If they do not, it will be no surprise if the public view of animal research is disproportionately colored by the relatively rare adverse events and the misrepresentations of animal rights activists. Many believe that it is possible—and perhaps acceptable—to ignore this part of reality in order to focus on more immediate demands for time, energy, and resources. Consider, however, that a fundamental part of the AWA, accreditation, regulation, and professional obligation is actually to ensure communication with the public that supports animal research.  Thus, it is our entire community who share a primary obligation to engage in the dialogue that surrounds us.

Speaking of Research Committee

Compliance at Work

One of the core principles at SR is that animal research should be conducted with the utmost care, responsibility and respect towards the animals.  All personnel involved in animal research should strictly follow the pertinent guidelines, regulations and laws.  Unfortunately, as in all human endeavors, there are isolated individuals who sometimes fail to adhere to established principles. The compliance system exists to detect such instances and take corrective action.

Recently, the USDA confirmed that an individual researcher at the University of Rochester was in violation of the Animal Welfare Act. The University was the first to discover the problem, reporting it to the USDA (the institution in charge of ensuring that the Animal Welfare Act is implemented), who confirmed the findings of non-compliance. The USDA were quick to identify the violations and publish the results, publicly, on their website.  This is an example of the compliance system at work.

As expected, animal rights groups, such as SAEN (warning: AR website), have used this opportunity to attack animal research, promising to “Expos[e] the truth to wipe out animal experimentation”. However, there are two important facts to consider:

  1. This was an isolated incident; and
  2. the system in place to deal with such incidents, responded appropriately.

We say the system responded appropriately in citing the University because the facts that are apparent about this case strongly indicate that this was an unacceptable deviation from established norms for the care and use of non-human primates in biomedical research laboratories.

With very few exceptions (for example, the need to restrict food in advance of anesthesia), monkeys must be fed every single day, with no exceptions or mistakes being permissible. What is worse, deprivation of food for multiple, consecutive days certainly produces profound distress in an animal that should have been identified by the combination of researchers, veterinary care providers and animal husbandry staff who were supposed to be carefully monitoring these animals every day. These animals were failed by the people who were responsible for their health and well-being. We hope that the Institutional Animal Care and Use Committee that supervises these research activities have taken comprehensive measures to ensure that an event like this never happens again.

Speaking of Research must condemn the actions the researcher in question.  Such behavior undermines the hard work that the rest of the animal research community does to ensure the highest standards of animal welfare. Furthermore, we commend the USDA and the University of Rochester for the actions they have taken to ensure that such violations do not occur ever again.

The success of our training, accreditation and compliance systems is not only measured by their ability to detect and correct isolated violations, but also in preventing them from occurring in the first place.   Here, we believe it is imperative to recognize the tens of thousands of persons that conduct their research with the utmost care, responsibility and respect towards the animals.