basis by a veterinary staff that must apply its didactic and experiential knowledge in managing them. These issues are fundamental to the success and credibility of any program of adequate veterinary care.

In my opinion, one of the most important sections of the Animal Welfare regulations is Section 2.33, Attending Veterinarian and Adequate Veterinary Care. This section in part states, “Each research facility shall assure that the attending veterinarian has the appropriate authority to ensure the provision of adequate veterinary care and to oversee the adequacy of the other aspects of the animal care and use.” The institution must make available appropriate facilities, personnel, equipment and services to allow the veterinary staff to use appropriate methods to prevent, control, diagnose and treat diseases/medical conditions.

An integral part of this program is providing guidance to principal investigators about issues that have an impact on the well-being of animals being used in research. We all know individuals we turn to for guidance and direction. Why do we rely on these individuals for guidance? It is really quiet simple. We respect them because they have established their credibility with us, and we recognize their professional competency. The key to the success of a program of adequate veterinary care is the mutual respect of the veterinary staff and the investigators, which leads to a confidence level that makes providing guidance the underpinning of the program of adequate veterinary care.

The key to the success of a laboratory animal veterinarian in an academic environment is earning the confidence of research colleagues, and we do this by using scientifically sound approaches in dealing with issues involving the use of animals on a given protocol. Our colleagues are accustomed to searching for answers that can be supported and defended with scientific data. With this approach, the necessity of having to implement USDA regulations and policies that are inconsistent with available scientific information compromises our ability to do our job.

Because I am already on record concerning how the existing language in Policy 11 undermines the ability of laboratory animal veterinarians to do their job, by forcing us to implement policy that makes neither scientific nor common sense, let me give you an example of why I fear additional changes in the language. Included in the information that I was sent a couple of weeks before this meeting was a 1995 draft of a HSUS document entitled, “AWA Classification of Pain and Distress in Animal Research: A Proposal.” That document includes a reference to Veterinary Service Memorandum 585.2, which provides guidance on pain and distress to area veterinarians in charge. In that memorandum, chronic pain is defined as follows: “Chronic pain results from a long-standing physical disorder or emotional distress that is usually slow in onset and has a long duration. It is seldom alleviated by analgesics but frequently responds to tranquilizers. . . .” The service memorandum proceeds to define anesthesia as “complete unconsciousness.” It is these types of definitions that must be aired in



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