The Federation of American Societies for Experimental Biology (FASEB) submitted comments on two requests from the United States Department of Agriculture (USDA) regarding animals in research. USDA regulates the care and use of certain species of animals in biological and biomedical research, and USDA regulations are enforced by the Animal Care (AC) division of the USDA Animal and Plant Health Inspection Service (APHIS).
The first Request for Information aimed to identify and reduce regulatory burden associated with compliance in USDA programs. FASEB identified two ways in which the workload of animal care staff, Institutional Animal Care and Use Committees (IACUC), and research investigators could be reduced. First, in a letter submitted to the Secretary of Agriculture, FASEB recommended allowing institutions to submit an estimate of animals used each year in their Annual Report to USDA AC rather than exact totals, which is now the common practice. Current USDA regulations do not specify that “exact” numbers of animals used or housed need to be reported annually. Allowing institutions to submit estimates would reduce the workload of IACUC and animal care staff.
FASEB also recommended eliminating keyword searches for alternative methods. Research investigators are required to consider alternatives to procedures that may cause more than momentary pain or distress to an animal. To satisfy this requirement, APHIS strongly encourages researchers to submit the results of keyword and literature searches. In lieu of these searches, FASEB recommended that APHIS encourage researchers to submit a narrative explaining why a proposed procedure should be used and how alternative approaches were considered. This would reduce burden placed upon the research investigator and IACUC.
The Federation also submitted comments on a petition to USDA to amend the Animal Welfare Act. The petition asked for additional clarification on the definition of “alternative” procedures as well as the establishment of regulatory standards to ensure that alternative procedures are appropriately considered. In a letter to the Acting Administrator of APHIS, FASEB suggested that the proposed changes duplicated existing regulations; would increase the burden of animal research without enhancing animal welfare; and would delay the approval, and ultimately the completion, of animal research.