None needed at this time.
The deadline for comments has passed. Thank you to all who took action.
Tell NIH Humane Animal Care is a Research Responsibility
Laboratories that use animals for experimentation and testing sense an opportunity to achieve a long-held goal: to weaken the already minimal care requirements of the Animal Welfare Act that have been on the books for more than 30 years. In addition, they are seeking to further shroud their activities from public scrutiny.
The National Institutes of Health, the US Department of Agriculture, and the US Food and Drug Administration are collaborating, supposedly to "to reduce administrative burden on investigators while maintaining the integrity and credibility of research findings and protection of research animals." What that actually means is that these federal entities are trying to figure out ways to reduce oversight of experiments involving animals and make those who conduct experiments less accountable to the public for their treatment of the animals, while making it look as if the they remain dedicated to "maintaining the integrity and credibility of research findings and protection of research animals."
Among other things, the research industry has long sought to (1) eliminate the required unannounced annual inspection by USDA veterinarians, (2) allow research plans to be reviewed by a single member of the institutional oversight body rather than by the full committee, and (3) end the requirement that researchers conduct a literature search for alternatives to procedures that cause pain or distress to the animals.
The NIH is soliciting public input on ways "to improve the coordination of regulations and policies with respect to research with laboratory animals." It is critical that you voice your opposition to any steps that could result in less oversight and lower standards of care for animals subject to experimentation. Please submit comments to the NIH by the June 12 deadline (this coming Tuesday).
Click here to go to the form on which comments must be submitted. As you'll see when you link to the comment site, the format is designed to discourage input from the public--all the more reason for you to comment! However, this is all you need to do: Using the suggested comments provided below, you can leave the first four boxes blank and submit the Section A Comments in the fifth box (labeled "5. Other approaches not previously mentioned"). You can then leave the next 5 boxes blank and submit the Section B Comments in the 11th box (labeled "6. Other tools or resources not previously mentioned").
Section A Comments
I urge the NIH to reject any changes to regulations and guidelines governing the treatment of animals in laboratories that would weaken protections for the animals, such as those suggested in the recently compiled report "Reforming Animal Research Regulations: Workshop Recommendations to Reduce Regulatory Burden." I am concerned that this information gathering is designed to justify relieving experimenters of already modest oversight and minimal responsibility for the animals they use and to allow them to avoid accountability and transparency. I can assure you that the public will lose confidence in the integrity and reliability of research conducted in the US if it feels that animal welfare is being sacrificed for the convenience of the laboratories.
- I object to reducing the frequency of USDA inspections of research facilities to less than once a year. Ensuring that laboratories experimenting on animals are adhering to the already minimal animal care requirements of the AWA is a modest amount of oversight and has been benefiting animals for more than 30 years--and likely ensuring better research outcomes as a result.
- I object to relieving researchers of the already minimal requirement that they conduct a literature search for alternatives to any proposed procedures that may cause pain or distress to animals.
- I object to allowing expedited review of protocols by just one committee member. Expedited review is not permitted when research involves "vulnerable populations," e.g., those, such as children or prisoners, who are unable to provide informed consent. Animals are not able to provide informed consent; therefore, expedited review is inappropriate. Full committee review is warranted.
Section B Comments
If the NIH is truly interested in "maintaining the integrity and credibility of research findings and protection of research animals," it will focus instead on doing the following:
- Aligning USDA and NIH regulations with regard to the species protected under the law by supporting an amendment to the Animal Welfare Act to include all vertebrates, and updating/expanding the requirements for handling, housing, and care under the law to be on par with those in the Guide for the Care and Use of Laboratory Animals. This would also bring US policy into line with that of other countries.
- Prohibiting the use of random source dogs and cats in research.
- Strengthening enforcement of the requirement to conduct a review for alternatives to any procedure that might cause pain and distress. It is widely felt that this review is barely given lip service. Using animals is a privilege, not a right, and every effort should be made to reduce, refine, and replace.
- Allowing facilities to submit the annual reports to the NIH's Office of Laboratory Animal Welfare and the USDA on the same schedule, so long as the requirements maximize animal welfare, transparency, public accountability, and ease of access.
Share this eAlert with your family, friends, and co-workers, and ask them to take action too. Thank you for speaking out on behalf of animals!