reasonable people should prevail and that USDA-Animal Care should not attempt to embrace pure fantasy—the hyperbolic HSUS 2020 Initiative —through the development of further regulations.

Acknowledged Contributions of IACUCs

In the span of the last 20 to 30 years, the vast reduction in endemic infectious diseases in laboratory animal colonies across the United States has probably already eliminated 90 to 95% of the total pain and distress potentially experienced by ALL laboratory animals used in biomedical research. Although this process was perhaps accelerated by the advent of IACUCs in programs in which this kind of communal engagement was necessary, it was already moving forward under veterinary guidance before the 1985 AWA amendments. The research community has received few accolades for this astonishing effort. Through the IACUC in collaboration with institutional veterinarians, we now have a structure and mechanism to tackle the remaining 5 to 10% of thorny pain and distress issues and to make sound decisions about the level of attention and intervention appropriate for problem areas on a case-by-case basis.


Multidimensional Impact

Even without AWA regulation or policy change, we have extended our stewardship to the laboratory rat and mouse used in research by conforming to the principles of humane care and “good science.” It is clear from the Animal Care Strategic Plan 2000 that the USDA-Animal Care anticipates expanding its authority in this area. This expansion could have a significant impact on the record-keeping requirements, on other dimensions of rodent care in research facilities, and on the cost of doing animal research (particularly where animal pain and distress may be involved). These potential effects give us reason to stress the need for caution and thoughtfulness in any revision of the USDA pain and distress categories or in the regulatory definition of the term “distress. ” In my view, the UDSA-Animal Care should rely on the NRC's Recognition and Alleviation of Pain and Distress in Laboratory Animals (NRC 1992) to define the term “distress” without being unduly prescriptive or trivial, and the autonomy and integrity of IACUC-scientist interactions should be preserved at the institutional level as indicated in the current AWA regulations.

Inclusion of Rodents

There are a number of other action verbs used in USDA-Animal Care Strategic Plan 2000, which indicates an aggressive agenda in the current year. I want to

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