would hamper a few research projects were based largely on speculation that other sources of animals could not meet this very small demand. The third task was to make recommendations, if necessary, for new or revised scientific parameters to guide their use, if Class B dogs and cats are deemed to be necessary for research.

Despite passage in 1966 of the Animal Welfare Act (AWA) in response to public concerns about the use of lost or stolen pets in research, these concerns persist. The Committee found that the USDA has made significant strides recently in enforcement of the AWA regulations and that the number of Class B dealers, who obtain some animals (including lost or stolen pets) from shelters and pounds, has decreased dramatically, particularly in the last 15-16 years. Whereas animals from Class B dealers represented 20 percent of dogs and cats used in research in 2002, by 2008 they represented only 3 percent and only a fraction of that percentage were used for NIH research. Of that fraction, animals from pounds and shelters, which is the group of animals with potentially valuable or unique attributes for NIH research, accounted for 20 percent of dogs and 61 percent of the very small numbers of cats from Class B dealers.

However, testimony provided to the Committee by USDA officials made it clear that despite new enforcement guidelines and intensified inspection efforts, not all origins of animals are or can be traced; therefore the USDA simply cannot ensure that lost or stolen pets do not enter research laboratories via the Class B dealer system. Furthermore, the administrative and judicial procedures necessary to enforce the AWA and ensure remediation of conditions that cause animal distress and suffering are inordinately slow, cumbersome, and ineffective. The Committee felt strongly that this is unacceptable.

Thus, in evaluating the information provided through testimony and from other sources, the Committee found the following:

  • Trends in the use of dogs and cats from Class B dealers in research suggest that for a variety of reasons (public opinion, pressure from animal protectionists, regulatory and financial burden, institutional policies, research trends, investigator choice), the Class B dealer system may soon become unavailable as a source of animals for research.

  • As long as the Class B dealer system persists, the biomedical research community will be subject to “negative press” and public concerns about lost or stolen pets ending up in research, no matter how rare such occurrences are or how well enforced the regulations.

  • The husbandry standards and humane treatment of animals are unacceptably variable among Class B dealers and not consistent with NIH standards of research animal care and quality.

  • In the absence of reported data, it is not possible to identify the



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