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Individual Statements by Members of the Committee on the Use of Laboratory Animals in Biomedical and Behavioral Research These individual statements appear exactly as the commit- tee members prepared them. The National Research Council neither endorses nor takes responsibility for the content of the statements. A1tTHUR C. GUYTON This statement is made for two purposes: first, to express severe disappointment that our Committee Report fails to make clear how seriously the Animal Rights Movement and increasing government regulation are unpeding essential medico research; and, second, to record at least one Scenting vote against the implication in the Recommendations section of the main report that the present regulatory framework will allow a healthy future for medical research. The success of the Animal Rights Movement in making medical research difficult h" been phenomenal in the last 3 years. One fifth of all States have already passed laws prohibiting release of pound arenas for medical research. And multiple animal rights- welfare organizations have announced publicly their priority goal to eliminate by law all release of pound animals for medical research within the next few years. Historically, most large-animal medical research has been performed in dogs and cats obtained from pounds 81

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82 INDIVIDUAL STATEMENTS because these are all unwanted animals and because the cost to society in using these animate is almost zero, which contrasts with a cost of many minions of doBars when alternative animals are used. Also, the Anunal Rights Movement has been surprisingly effec- tive ~ getting the Federal Government to establish very restrictive regulations on medical research. Some of the most blatant of these are: 1) The necessity to obtain prior approval before performing each type of animal experiment, a requirement that often delays essential research as much as two months. 2) A requirement that all major survival surgery on rabbits or larger animate be performed in a sur- gical operating room suite costing an average of a quarter million dollars add directed by a high-salaried veterinarian, even though the veterinarian usually is not a trained surgeon. In the past, this type of surgery has been done exceedingly successfully in the investigator's own laboratory at no extra cost. 3) Very arbitrary regulations for specific cage sizes, and even these have been changed on multiple oc- casions, costing hundreds of mullions of dollars throughout the United States. These are only examples of a litany of such regulations. The net effect has been an extreme increase in the cost of ani- mab used ~ research as well as cost of lost time and effort by the investigator. Including the expense of meeting federal regulations, the cost of dogs and cats used in research, together tenth the cost of their care, now averages more than $1,000 per animal in some institutions, and this does not count the cost of the research itself. Historically, when an~rnals were readily available on a days notice from local animal pounds, the cost of dogs and cats was very little. Role of Veterinarian Professionalism in Imposing New Difflcut- ties for Medical Research. Veterinarian scientists have made and are making major contributions to medical research. However, in the last three years, there has been a proliferation of new government regu- lations requiring vastly expanded and costly roles for veterinarians as regulators of virtually all animal-bed biomedical research. This presumably has come about because thme government agencies that make the regulations (for example, the Inspection Agency of the De- partment of Agriculture) are staffed to a great extent by professional veterinarians, and they naturally believe that others cannot have the expertise to work properly with animals. Yet, we all know that medical professionalism, with doctors regulating doctors, and legal professionalism, with lawyers regulating lawyers, always under the pretense of high principles, make medical and legal services extremely expensive to the public. In a similar manner, this new proliferation

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INDIVIDUAL STATEMENTS 83 of animal-control regulations requires a very costly layer of veterinar- ian regulators who do not actually participate in the research itself. The vast and superb medical research accomplishment of the put has been achieved without this new bureaucracy. Is it truly needed now? Arid if so, ~ it not also needled for the pounds and animal right~weifare shelters which house and kiD 50 times as many dogs and cats each year as does medical research? Misplaced Faithin ~Alternatives~toAnimaiResearch. TheCom- niittee Report contains an entire chapter on Alternative Methods in Biomedical and Behavioral Research. Unfortunately, the prorrunence Of this chapter gives false hope that animal-based medical research can be done with substitutes for animals. Unless we substitute human beings as the research subjects, this is very rarely true. Therefore, it is seriously wrong for the Committee Report to give such false ex- pectation. The Animal Rights Movement h" Creaky made a strong effort in Congress to divert as much as one-fifth to one-half of ah health-related research money to studies using only animal ~alter- natives,~ ~d our report will likely be used to suDnort further such efforts. or Desperate Need for Help in Combating the Initiatives of the An- imal Rights Movement and of Regulatory Bureaucracies. It is clear that the Annnal Rights Movement, with the help of new and expand- ing federal, state, and local laws, is rapidly making much animal research cost ineffective as well as extremely wasteful of the research scientist' time. Many of the regulations appear not to have been thought through, such as the requirement for a quarter of a million dollar operating room suite to perform operations on rabbits. The new federal regulations are similar to those established in Europe several decades ago; large animal research is now close to annihilation in Europe. As a result, the Europeans have made very little contribution in certain types of medical research, for example in cardiovascular surgery, except when the research could be done on human bergs themselves. Therefore, the medicad research corrununity desperately needs strong help in combating both the Anunal Rights Movement and the growing regulatory bureaucracies. Our committee has failed to produce a document that will be helpful for tiers purpose. This is understandable because the committee itself includes many members who have never worked in anunal research ~d particularly includes two Presidents of national animal Welfares organizations. Considering the rapidly expanding restrictive and time-wasting

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84 INDIVIDUAL STATEMENTS regulatory environment, I cannot in all good conscience recommend to young researchers that they pursue careers In those types of med- ical research that require the use of animals. How will it be possible to make many new advances ~ medicine? CHRISTINE STEVENS The report refilses to face the widespread, ingrained problem of unnecessary suffering among the millions of laboratory animals used yearly in our country, nor does it make so much as a passing reference to the serious problem of poor research using excessive numbers of animals. The single recommendation, approved by majority vote, to im- prove the treatment of about 85% of research animals was reversed at the only Committee meeting ~ did not attend. The reversed recom- mendation requested the Secretary of Agriculture to issue regulations under the Animal Welfare Act extending its protection to Ace, rats, birds and farm animals used for biomedical research. Ironically, for lack of application of the minimum standards of the Animal Welfare Act, conditions of extreme neglect and abuse developed in a rodent laboratory under the jurisdiction of a Com- nuttee member. Dozens of photographs documenting long-~tanding filth, holes in wads and roof through which wild rodents gam access, hazardous hancIling of carcinogens and other improprieties which could confound test results and endanger personnel, were sent me by a concerned worker who asked my help in obtaining desperately needed reforms. Another member of the Committee indicated that his institution doesn't know the number of mice and rats used and if reported, it is not the truth. The report was to have provided new factual information on numbers of animals used, but the study was never conducted. Thus, there is no new quantification on animal use as announced by NAS when the Committee was formed. Readers are led to believe that animal use, especially of primates, is declining, e.g. The substantial decrease (47 percent) in the use of nonhuman primates... (p. 61~. But USDA figures document an increase of 26.48% from 1986 to 1987. Total animal use also increased as did animals reported by the institutions as experiencing unrelieved pain. The chart (pp. 2~21) omits available USDA data on wild animals. Although the report claims to favor animal welfare and oppose

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INDIVIDUAL STATEMENTS BS animal rights, the net effect is a de facto undermining of animal welfare. ~ was shocked by the attitude of Committee members who as sorted that we have no moral obligation to animate and expressed hatred of the idea of having a report that puts emphasis on alter- natives. Committee members decried the public notion that animus have rights. If they do, one observed, ~ don't think we have the right to do an~rnal experiments. During a cliscumion of current NTH regu- lations requiring that grant proposals provide data that will advance knowledge of irnunediate or potential benefit to humans and animals, members asked one another whether they agreed. We agree or we don't get any money was the response. It was surprising to hear the assertion that everybody cheats and prevaricates. Although it is well known and widely acknowledged that the health and welfare of experimental animals is essential if sound oh servations are to be achieved, Committee members insisted that animal welfare rules should not be seen ~ a method of improving science. Material presented by Committee members on the benefits of regulation of animal experimentation and the history of such reg- ulation in Europe was cut from the report which instead makes the unreferenced charge that in Come countries" unspecified Strict legmIation" ho Deduced potential contributions to human welfare. The modest U.S. legislation is unreasonably characterized as ha large body of laws and regulations" by which institutions and in- vestigators are said to be "unnecessarily confused and burdened. Regulations under the 1985 amendments to the Animal Welfare Act have been held up by the very people who want to claim that "hu- mane care and use of laboratory animads characterize the scientific community." Virtually no acknowledgement of outstanding research results from scientific work appears In the report unless they were based on the use of vertebrate animals. Yet: a substantial proportion of NIH funds are dispensed for epidern~ological and cImical research much animal experimentation produces no significant re- sults leading scientists have publicly criticized erroneous conclu- sions resulting from large-scale anneal experiments. These exemplify matters on which readers of the report should

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86 INDIVIDUAL STATEMENTS receive objective information. But objectivity ~ incompatible with the ~strong, hard-hitting report" promoters of animal experiments demand. To prevent cruelty and theft by dog dealers and to encourage painless experunents in place clef painful ones, ~ recommended "That dogs and cats obtained from public pounds be 1) used only for non- survival experiments under full anesthesia in which the animal is first rendered unconscious and never aBowed to recover consciousness but passes directly into death, and 2) obtained directly by the registered research facility from the pound, not through a dealer. The recom- mendations on this subject (pp. 10, 73) do not accurately represent my proposal or my position. The report faire to take account of animal fear and pain. The assertion that Inmost research animus are humanely killed at some potty is unreferenced. Not surprisingly, since there is no reporting system in place which would enable this assertion to be documented. We do not know how many animals are I) kiDed hu- manely, 2) killed inhumanely, or 3) left to die unattended without pain relief. The executive summary (p. 6) erroneously states that according to law: "... all animals used receive adequate presurgic~ and post- surgica] care and pain-reliev~ng drugs. But 130,373 anneals were denied pa~n-relie~ring drugs under the law's exemption provision dur- ing 1987, according to the annual reports submitted by Registered Research Facilities to USDA. Nothing ~ the report even hints at the long-drawn-out pain and suffering undergone by many laboratory animals. Instead, they are characterized as ~niinorn (p. 63) and a false claim is made that ad serious violations have resulted ~ suspension of funding and/or imposition of fines. Mundane facts revealed in inspection reports of major research facilities by veterinary inspectors of the USDA are ignored. Typical findings of inspectors include: most rabbits without water excessive build up of manure and hair overcrowding moldy feed dogs with distemper piles of rodent droppings throughout building dogs standing in water rat holes numerous phenomenal number of roaches

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INDDYIDUAL STAT~E:NTS 87 surgical site for implantation of electrodes into primates' brains conducted in office off busy hallway, only chemical sterilization of equipment monkeys wet and smeared with excrete dog needs reellturing sick kitten not under care of veterinarian. Blood Tom rectum and paresis of rear limb dogs sitting ~ urine and feces. Such conditions for anneals are ~ source of uncontrolled vari- ables that skew research results, thus wasting scientific effort ancI taxpayers' money. The only acknowledgment of this suffering ~ one sentence: "From time to time some few members of the scientific community have been found to mistreat or inadequately care for research anunab." The Executive Summary even waters down this feeble statement by omitting the word ~mistreat." A balanced report should recognize the severity and extent of the problem. It should recognize the essential role of sound regulation to pretreat neglect and abuse of research animal, for the animals' sake add research accuracy. It should vigorously advocate: I) research and development of alternatives, i.e., methods to reduce, refine or replace final tests* 2) training laboratory personnel in humane care and treat- ment of animals 3) choice of least painful procedures by investigators 4) substantial government funding for data bases designed to: reduce unintended duplication of animal tests, facilitate distribution of information on alternatives and malce non-warm-blooded animal systems as fable to investigators and students. *An earlier version stated "Mammalian usage can be decreased by various techniques of replacement and reduction... More such models will become available particularly if additional research is devoted to this effort."

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