Sir

We at the Humane Society of the United States strongly agree with your Opinion article “Rights, wrongs and ignorance” (Nature 416, 351; 200210.1038/416351b), that the science of animal suffering and cognition should be given higher priority. The public is often told that the pain, distress and suffering of research animals are already being minimized. But given the lack of scientific knowledge about these issues, much more can and should be done to develop knowledge to identify, assess, avoid and/or alleviate such suffering.

Our current knowledge of animal suffering and cognition is relatively isolated, and the principles too rarely applied in animal research. Scientists engaged in research on farm-animal welfare, for example, should be consulted on how to investigate animal suffering in laboratories. Widely used techniques, such as the use of carbon dioxide for rodent euthanasia and the creation of genetically modified animals, should be reviewed and discussed, and a consensus should be reached on the level of suffering caused. We challenge all stakeholders, including the research community, supervising agencies and the animal-protection community to tackle these issues together in a coordinated way (see http://www.hsus.org/ace/11350), to minimize animal suffering and to reduce the uneasiness that we all experience (biomedical scientists included) when animals are harmed in the cause of scientific progress.

In your earlier Opinion article “Time to cut regulations that protect only regulators” (Nature 414, 379; 2001), you rightly state that the primary purpose of the Institutional Animal Care and Use Committees (IACUC) system should be the protection of laboratory animals from pain, distress and harm. We are no more in favour of unnecessary paperwork than the research community. We have proposed a revision of the pain and distress classification system that would focus attention on the riskier projects and could help avoid unnecessary paperwork for projects that carry no risk of pain and distress — but the research community has protested vociferously against our suggestions.

You are, however, incorrect to state that IACUC reviews used to be carried out after a grant application had passed an initial approval stage. This has never been the case, although the system may indeed change soon, in line with the recent changes by the Institutional Review Boards (IRBs) for human subjects to the 'just in time' system you outline, to cut down unnecessary paperwork. You are also incorrect to state that cross-talk between institutions is not permitted: various publications advise on procedures in this regard, though we agree that far too little is done.

Any fear among institutions is being driven by the IRB system, not by the IACUC system. Death or injury to a human being generates risks of adverse publicity and litigation that are orders of magnitude greater than when laboratory animals are used.