SCHWINDAMAN, CONNOR, MCPHERSON, PIERCE, NORMAN, CASS, PARKER & HARMISON 1275 
is really contrary to a basic philosophy of our 
policy for research grants and training grants 
because the money goes to the institution. The 
institution is considered the grantee, not the 
man who's directed the project. So, this regula- 
tion, by emphasizing the investigator's respon- 
sibility, really was contrary to our long-stand- 
ing philosophy and did not put the responsibility 
where we thought that it should be — on the 
corporate entity that received and managed the 
funds that the man used to carry out his proj- 
ect. This was one reason for saying something 
more than what we had been saying for a num- 
ber of years (to put the responsibility where 
the money was) because the only control that 
we really have over how our grants, contracts, 
and awards are carried out is the disbursement 
of money. In other words, the only way that we 
could stop something that was not right would 
be to withhold funds from it. This is not an 
insignificant method of control, but this really 
didn't speak to that point. That was one rea- 
son why many people thought it ought to be 
changed. 
Another fact is that over the years our study 
sections and councils have seen a number of 
projects submitted to NIH and the other Public 
Health Service agencies that did suggest that 
the investigator proposed to do something 
that really wasn't very nice with animals. I 
guess this averages about four or five proposals 
a year, not many, but enough to develop a cer- 
tain amount of concern in many peoples' minds 
as to whether some of the institutions that were 
receiving our grant money really were aware 
of what some of their investigators wanted to 
do with animals because some of them were 
rather horrendous. We have a good screening 
mechanism for this sort of thing called a Study 
Section. As you know, these are panels of out- 
side consultants from your own universities 
that review our grant proposals and take note 
not only their scientific merit but of these kinds 
of things. Over the years, a handful of these 
projects that were quite off -base had been called 
to our attention. Certainly the development of 
the laws administered by USDA has had its im- 
pact on our thinking, both the original Act and 
the one that was amended as of Christmas Eve 
one year ago. 
Another thing about these so-called "problem 
projects" that we see from time to time should 
be emphasized. I think without exception they 
were recommended for disapproval and never 
funded. This simply is a reflection of the fact 
that if an individual is willing to practice poor 
husbandry he probably is a rather poor scien- 
tist, and the way animals are treated, held, 
maintained, and cared for would certainly af- 
fect the expected outcome of the research that's 
going to be performed on them. So if it's part 
of our mission to improve the quality of bio- 
medical research, we felt that we ought to en- 
courage institutions and their employees to do 
the best they could about the way they deal with 
animals, both in the holding facility and in the 
laboratory itself. 
A third thing that certainly must have influ- 
enced NIH to develop this administrative policy 
is the longer experience with the more inten- 
sive requirements on human subjects, a thing 
that some people consider to be even more im- 
portant than animal welfare. This developed 
originally in 1966 and has become more and 
more precise and detailed in its requirements. 
Experience with it has shown that its existence 
has resulted in our receiving fewer and fewer 
proposals that would be considered problems 
so far as what the man intended to do with hu- 
man beings. I'm sure that we have hoped that 
the same effect will take place on laboratory 
animal research. 
Last but not least, we certainly are aware, 
as everybody is, of the increased public interest 
in all aspects of scientific ethics. I think that 
every scientist, particularly those who are 
dealing with living systems, are under closer 
scrutiny than they ever have been before, so 
that we are not really quite as surrounded by 
ivory towers as we once were. I don't think 
anybody will consider that an unhealthy situa- 
tion, but it's one that I think we ought to con- 
sider. 
So, these are some of the reasons that I would 
give as why NIH should have administrative 
requirements tied to its grants and contracts 
mechanism. That is a point that should be 
emphasized in comparing it with what USDA 
administers. USDA, Dr. Schwindaman's oflfice, 
administers a law. We are talking about an ad- 
