our investigators who are trained at the molecular or cellular level have very little experience with whole animal research. Often, the veterinarian is able to enhance the overall design of a research protocol, which surpasses regulatory requirements but supports good scientific method.

In consultation with the veterinarian, each of our investigators estimates the number or the percentage of animals that may experience pain and distress in each study. This information is provided in the protocol submitted for IACUC review and approval. If any animals are likely to experience pain or distress, the investigator must also provide a scientific rationale for proceeding with the study. Because we understand that prospective estimations of pain and distress will not be 100% accurate for 100% of the studies, especially when working with novel compounds, our IACUC requires investigators to notify the committee immediately if, during the conduct of their research, there are any deviations from the estimated number of animals that experience pain or distress. In addition, at the end of each government fiscal year, every investigator is required to report the actual number of animals that experienced pain or distress.

IACUC

As part of the protocol review process, the IACUC should evaluate the methods proposed to prevent or minimize pain and distress. The IACUC also has the responsibility to consider the scientific rationale for conducting a study that has the potential to cause pain or distress in laboratory animals and potential benefits to society. I agree with previous statements that anti-inflammatory agents and antibiotics, in addition to anesthetics, analgesics, tranquilizers and sedatives, are effective in relieving and preventing pain and distress. I support the USDA's proposed change that would include the use of all of these agents in Category D.

Veterinarians

A qualified veterinarian or animal technician should be involved in assessing the animals during the course of the research and provide pain relief whenever possible. More than 30 years ago, the AVMA adopted an oath that requires veterinarians to protect animal health and relieve animal suffering, which is very pertinent to today's discussion. However, veterinarians are also expected to use their scientific knowledge and skills for the benefit of society and to promote public health and the advancement of medical knowledge. We cannot forget that there are still many disease entities that we have yet to conquer and that this will depend on animal research. Therefore, in some studies, the veterinarian may need to consider the need to treat animal pain and distress along with the ultimate goals of the research and the potential benefits to both humans and animals.



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