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Pain and Distress: USDA Perspective
Pages 3-8

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From page 3...
... We cannot talk about any of these things without also considering the potential impact if the USDA should decide to regulate rats, mice, and/or birds. The burden that would be imposed would not be confined to regulating those species, but also would involve minimizing pain and distress in those animals and imposing reporting requirements because they represent 90% or more of the animals being used in biomedical research.
From page 4...
... This policy, which requires consideration of alternatives to painful and distressful procedures, states that the database search remains the most effective and efficient method of satisfying the requirement of considering alternatives to painful and distressful procedures. At the same time, it recognizes that this method might not always be the best, or it might be one of multiple methods, used to satisfy the requirement.
From page 5...
... I mentioned earlier the concept of prospective versus retrospective reporting. Prospective reporting of pain or distress involves classifying animals in categories based on anticipation or expectation that the animals are likely to experience pain or distress and whether one plans to use any of the pain-relieving medications.
From page 6...
... It would be a bit of a leap from where we are now, since current regulations recognize only anesthetics, analgesics, and tranquilizers or other painrelieving medications as a means to appropriately classify procedures in Column D Column E Description: Teaching, testing, or experiments involving pain or distress for which the use of appropriate anesthetic, analgesics, or tranquilizing drugs would have adversely affected the procedure' s results or the interpretation.
From page 7...
... So, to provide a ridiculous example, one could perform thoracic surgery on an animal, provide postoperative analgesia consisting of an aspirin, and perhaps appropriately categorize that in Column D I think that is subject to debate, but there is nothing in the regulation that requires any evaluation of whether a particular pain and distress relief was effective.
From page 8...
... When we publish this Notice in the Federal Register, which we hope will be very soon, we hope that you will comment. We are anticipating a 60-day comment period for the definition of distress as well as the concept of changing our current pain and distress categorization scheme.


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