While examining the policies of the AWA, Rosen missed a few steps. For example, the congressional statement of policy specifies both that the intent of the Act is “to insure that animals intended for use in research facilities ... are provided humane care and treatment1” and that “measures which eliminate or minimize the unnecessary duplication of animals can result in more productive use of Federal funds; and ... measures which help meet the public concern for laboratory animal care and treatment are important in assuring that research will continue to progress1”. While Rosen quotes from §2143(6)(A) of the Act, he should read a little more of this section, which authorizes the Secretary to promulgate standards that address humane handling, care, treatment, and transport as well as focus specifically on pain and distress. The mandate of the IACUC is to oversee these issues at the institutional level. Similar language is in the AWA regulations. In recognition of the possibility of the scenario raised by Rosen, the United States Government Principles for the Utilization and Care of Vertebrate Animals Used in Testing, Research and Training principle IX states that “... the decisions should not rest with the investigators directly concerned but should be made, with due regard to principle II, by an appropriate review group such as an institutional animal care and use committee2.”
The spirit of the law is to ensure welfare of the animals and not to impede research. The law specifically recognizes the benefits to humans and animals that accrue from the use of animals for research. Most institutions do not expect its investigators and employees to be familiar with all the nuances of federal laws and regulations, and the additional layers of state and local laws and ordinances. The IACUC, in concert with the Institutional Official (IO), has the mandate to ensure that standards are satisfied. Increasingly, IACUCs are using the resources of specialized staff members or the legal affairs department to develop interpretations of applicable laws and regulations. These interpretations usually are in the form of guidelines or policies that help investigators and Committee members to address recurring or difficult issues. Rosen has misconstrued the IACUCs' role. Instead of seeing the IACUC as fostering an environment in which the highest quality of research can proceed and advocating for institutional resources to improve the animal care program, he views the IACUC as an impediment to research. Rosen's comments and attitudes reflect a level of distrust that could plague the entire institution. The IACUC, in conjunction with the IO, should recognize and work to dispel this weakness in the program. A concerted effort is necessary to ensure that all individuals involved in the animal care program are aware of the overarching as well as specific functions of the IACUC.
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