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A View from the Trenches
Pages 44-52

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From page 44...
... Next I will explain how it is that I came to be standing here today. I will then explain why I cannot support efforts to introduce new language to the current definition of pain, the addition of a definition for distress, or changes in the current annual reporting process by revising the current Animal Welfare Policies.
From page 45...
... I am not asking for more regulations, I am asking for a process that gives the scientific community a full opportunity to address the available scientific information on pain and distress and its application in clinical practice. I believe that available scientific information strongly speaks for not adding additional language to the regulations/policies, and I believe that a formal public comment period will make this fact abundantly clear.
From page 46...
... With this approach, the necessity of having to implement USDA regulations and policies that are inconsistent with available scientific information compromises our ability to do our job. Because I am already on record concerning how the existing language in Policy 11 undermines the ability of laboratory animal veterinarians to do their job, by forcing us to implement policy that makes neither scientific nor common sense, let me give you an example of why I fear additional changes in the language.
From page 47...
... · Most importantly, they accept the fact that the well-being of the research animals that they use is critical to the success of their research. At a time of tremendous advances in biomedical research, unprecedented growth in the federal research budget, and tremendous competition for those dollars, the new generation of investigators does not just accept the need for quality animal and veterinary care programs, they demand it.
From page 48...
... and scientific information is changing daily. The regulatory process is slow because of the many steps required to change regulations in our democratic society that protect the regulated community from counterproductive regulations.
From page 49...
... The membership has provided and is committed to providing hundreds of thousands of their personal dollars to support research to improve animal well-being. Instead of spending our time and resources developing and debating paper definitions, let us make a commitment to support the research that produces information to make it possible for the laboratory animal community to better recognize, manage, and alleviate pain and distress.
From page 50...
... Practicing scientists cannot afford to waste money creating unnecessary pain and distress in animals. They are under tremendous pressure to produce and they cannot afford to lose animals due to improper management.
From page 51...
... DR. BENNETT: I believe it is important to note that unless a rule appears as a formal regulatory change, we do not get as much of the scientific community involved in the comment period because they expect these to be adopted ultimately.
From page 52...
... I am arguing that instead of motivating them, those factors comprise part of reality, and that part of reality makes our job as laboratory animal veterinarians sometimes a lot easier to do.


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