training and competence of individuals (ethical, legal, and specific skills), provision of veterinary care, viable sources of animals and transport, and inspection of facilities.

There are consequences of applying core principles, MacArthur Clark suggested. First, some proposals may not be considered justifiable. They may, for example, involve long-lasting severe pain that cannot be alleviated or the cost-benefit assessment may not balance. Second, bureaucracy may become part of the evaluation of “marginal” projects. When challenged with a difficult decision, assessors ask more and more questions, resulting in what is sometimes called “paralysis of analysis.” Eventually, either the project is approved or the applicant gives up. If the project is approved, it is often on the basis that the work will be heavily monitored, MacArthur Clark noted. This process occurs equally in different models of governance (both the U.S. self-regulated Institutional Animal Care and Use Committee [IACUC] model and the European Union [EU] centralized Competent Authority).

Project Authorization Without Bureaucracy

MacArthur Clark raised the concept of “thin slicing” as an approach to making project authorization decisions. The concept is that spontaneous decisions are often as good as, or even better than, carefully planned and considered ones. The goal would be to make better decisions early on and foster compliance without bureaucracy. Another goal would be to identify marginal projects as early as possible and develop a separate process to review them and facilitate faster decisions. Reject the project and provide reasons, or accept the marginal project and build in milestones that are not overly restrictive, MacArthur Clark asserted. Once the decision to authorize has been made, it might be easier to focus on other aspects of approval, such as implementing the 3Rs. MacArthur Clark noted that efficient processing could reduce costs while supporting science and welfare.

Training and Competence

From the outset, the European commission declared its intention that there should be free movement of staff, including scientists, veterinarians, and animal care staff, throughout Europe. This means a need for common training standards. Training, however, does not necessarily equate with competence, MacArthur Clark noted. Individuals acquire competence through their work, so in addition to training and supervision, a mechanism to maintain competency could be included.

Another core principle could be the delivery of appropriate and relevant training that is acceptable and palatable to those who receive it.

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