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USDA Employee Survey on the Effectiveness of IACUC Regulations

United States, Department of Agriculture, Animal and Plant Health Inspection Service, and Animal Care Division
Animal welfare--Law and legislation
Executive Summary: USDA APHIS Animal Care conducted a brief mail survey of 40 of its field employees who are Veterinary Medical Officers (VMOs) and 9 of their supervisors to assess their opinions about the effectiveness of USDA’s current approach to ensuring humane care and use of animals at research facilities through the mechanism of Institutional Animal Care and Use Committees (IACUCs) and to collect ideas about how to improve it. All VMOs and supervisors responded to the survey. Collectively, the VMOs inspect more than 1200 facilities. Seventy percent of the VMOs have 8 or more years experience inspecting research facilities and have had an opportunity to observe the effect of the IACUC regulations since their inception. Ninety four percent of the VMOs who answered felt that the overall effect of the IACUC regulations has been to improve the welfare of research animals. Those VMOs who have the highest number of research facilities (35 or more) and spend 60% or more of their time inspecting them feel the strongest about it- that the welfare of research animals has been “Greatly Improved” by the IACUC regulations. The VMOs rate the regulations, the functioning of IACUCs, and Animal Care’s enforcement of the regulations Medium to Medium High. The VMOs also rated the IACUCs’ effectiveness on a range of specific functions. The pattern across these functions was relatively consistent; IACUCs seem to be doing well at functions related to setting up the administrative structure and developing the process, but not as well at monitoring and follow through. These findings support the conclusion that the IACUC regulations are generally effective, and that great strides have been made in improving humane care and use of animals at research facilities since the regulations were adopted, but the task is not finished yet. APHIS should not spend resources on a major overhaul of the IACUC regulations in general, but should work toward refining the system that has been established. The industry response to the system is evolving and research science is evolving. APHIS needs to stay current with these changes, needs to be consistent in what we require. The regulations were designed to allow the government to keep up as this process unfolds. Animal Care VMOs report that some of the problem areas that need to be refined are: the search for alternatives, review of painful procedures, and monitoring the investigators’ use of animals to ensure compliance with approved protocols and standard operating procedures. An estimated 600 to 800 facilities have had trouble with the search for alternatives, 450 to 600 with review of painful procedures, and 350 to 400 with monitoring for compliance. The high level of problems reported by VMOs supports the need for a review of Policy 12, “Search for alternatives.” APHIS should, in conjunction with AWIC, OPRR, and industry, develop a way to appropriately encourage searching for alternatives to painful procedures. The VMOs answering the survey identified a great number of innovations that various facilities have made that may have merit for distribution. Most of the ideas they identified for improving the regulations seem to involve clarifying the roles of the Institutional Official and the IACUC members and strengthening the IACUCs’ authority. A number of VMOs advocate issuing a policy, guideline or educational materials that would close the gaps and refine the system. Animal Care needs to provide clear guidance to industry and the VMOs on what constitutes a painful or distressful procedure for AWA purposes, expectations to minimize pain and distress, and how to accurately report on them. A large number of VMOs advocated attending IACUC meetings in order to educate the members on regulation requirements and facilitate communication with them. A large number also recommended that they should be allowed to take the time to be more thorough, review records in more detail, comprehensively evaluate sensitive protocols involving surgery, pain and distress, talk to Principal Investigators, and do occasional audits of Category D and E procedures. Downloadable forms and checklists they could share with facility personnel would be a help to them. A list of training ideas for both IACUCs and VMOs is included in the report. Some of their needs are the same and could be met in joint sessions offered thorough the Animal Welfare Information Center and similar venues. Many of the VMOs’ other training needs could be met by allowing them to join their colleagues on research facility inspections, observe types of research being conducted, and discuss ways that their colleagues resolved certain problems. Policy clarifications and guidelines, when completed, would require a more formal approach than participating with colleagues on joint inspections. Depending upon how extensive they are, they would probably entail developing training sessions focusing specifically on IACUC compliance.
Animal and Plant Health Inspection Service
Animal Welfare Act History Digital Collection