or policy. How then, from a regulator's standpoint, would you ensure uniform interpretation of categories?

DR. RICH: Your question is excellent. I do believe that exemplars are helpful. I suggest that we, as a community, can agree on some exemplars but still avoid encouraging checklist mentality inspections of university animal usage, which lack a thoughtful approach to what was actually done. I believe we are ill-served when checklists and clipboards replace good judgment. However, having some community consensus regarding certain procedures would ensure that appropriate corrective measures would be taken if an inspector found substantial discordance from this consensus in a particular institution's categories of procedures or protocols. However, to the extent that codification of exemplars would tend to focus on process rather than outcomes, I believe this approach could actually make inspection and enforcement less, rather than more, fair and effective.



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