regulation would require a rule change. It is either a two- or a three-step process for the rule change, which requires, at a minimum, publication of a proposed rule, public comment period, review of those comments, and publication of a final rule. In this case, we will start with a three-step process but include in the beginning an advanced notice of proposed rulemaking and request for comments. The next step, if we decide to proceed, would be a proposed rule. There will, indeed, be ample opportunity for the scientific community and all interested parties to have some input into that process.

DR. BENNETT: I believe it is important to note that unless a rule appears as a formal regulatory change, we do not get as much of the scientific community involved in the comment period because they expect these to be adopted ultimately. I formed that impression when I worked with organizations to write responses that appeared in the Federal Register.

DR. HAMPSHIRE (Victoria Hampshire, Advanced Veterinary Applications): Are you in fact supporting a revision to the regulation and/or the definition of an attending veterinarian?

DR. BENNETT: No. I am saying that the role of the veterinary staff would be strengthened in terms of the issue of distress if it were clearly pointed out that investigators should consult with a veterinarian when a proposal will have the potential for creating not only pain, but also distress. The law does not state that now. It only refers to pain.

DR. GEBHART (Gerald Gebhart, University of Iowa): I want to remind people that the way we have been talking about pain and distress seems to suggest that they go hand in hand. However, pain does not inevitably lead to distress; and pain, as Dr. Rowan said, is not a major concern in many respects because it may be addressed with the appropriate use of analgesics. By establishing a category that includes both pain and distress (Category 1, 2, and so forth), even if there were some pain but no distress present, or if only distress were present, an investigator's rating would imply that both conditions were indeed present. I believe we need to be careful about associating those two conditions as always being related because they are not necessarily so.

DR. BENNETT: One of the points made previously that I found interesting was that these reports are different from retrospective reports. I cannot imagine that any institution could complete that report without some type of retrospective reporting process that involves looking at the animals and evaluating these things.

DR. HAYWOOD (J. R. Haywood, San Antonio): We have discussed these reports as documents that actually provide us with information. However, maybe we should think about why we are actually filling out these reports. What function do these reports truly serve to help the animals?

MS. LISS (Cathy Liss, Animal Welfare Institute): I am delighted with what appears to be current support for the 85 amendments to the animal law and actually a cry for a bit of strengthening of those 85 amendments. I am delighted to



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