TABLE 2 Policy 11: Minimization of Pain and Distress—Draft

  • Defines distress

  • Recognizes other methods of relief—therapeutic agents, specialized nursing care, behavioral conditioning

  • Recognizes that a single procedure may be placed in column C, D, or E, depending on circumstances

  • Explains prospective versus retrospective reporting

  • Provides column descriptions and classification examples

This definition of painful procedure is direct from the regulations: “Any procedure that would reasonably be expected to cause more than slight or momentary pain or distress in a human being to which the procedure was applied, that is, pain in excess of that caused by injections or other minor procedures.” The definition of distress in the current version of the rewrite of Policy 11 is as follows: “A state in which an animal cannot escape from or adapt to the external or internal stressors or conditions that it experiences resulting in negative effects upon its well-being.” We certainly welcome your comments on this working definition of distress. This definition of distress is for AWA purposes. No doubt there are other scenarios and situations where this definition of distress might not be appropriate.

We believe that the definition of distress for AWA purposes must be in excess of that which an animal would experience by routine husbandry or handling practices. In other words, simply caging an animal in a laboratory would not be considered distress in the context of the AWA and our regulations. Additionally, to distinguish stress from distress is critical in that the requirements for minimization of pain and distress apply to “distress” and not to “stress.”

We believe adherence to Principle IV of the US Government Principles is important and have included it in our working draft of the policy. It states that unless the contrary is established, investigators should consider that procedures that cause pain or distress in human beings will cause pain or distress in animals.

I mentioned earlier the concept of prospective versus retrospective reporting. Prospective reporting of pain or distress involves classifying animals in categories based on anticipation or expectation that the animals are likely to experience pain or distress and whether one plans to use any of the pain-relieving medications. In contrast, retrospective reporting is based on the actual observed presence or absence of pain or distress and the actual use or nonuse of pain-relieving measures.

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