HUMANE TREATMENT OF ANIMALS USED IN RESEARCH 21 
he would generally be making demonstrations, not pursuing research. Delays 
incurred in scheduling research programs contingent upon project approval 
by the Commissioner could cause contract delays that would frustrate the entire 
research effort. 
Section 10(a) provides that letters of qualification to use animals in research 
may be issued only to persons holding doctoral degrees in medicine, veterinary 
medicine, physiology, psychology, or zoological science. This provision would 
preclude, unreasonably, many qualified instructors who have only bachelor’s 
or master’s degrees from obtaining letters of qualification, thereby hampering the 
educational efforts in many of our teaching institutions. 
Sections 12 (k) and 12(1) provide for records to be maintained of all experi- 
ments performed to include what specific animals were subjected to what tests 
and with what results, and for all animal enclosures to be so marked as to in- 
dicate the nature of the experiment involved. These recordkeeping requirements 
proposed to be kept for the Commissioner and for State law-enforcement agen- 
cies would be in addition to those already required to be kept for the sponsoring 
agency and research institution, and would necessitate a large amount of un- 
necessary clerical work which would divert funds from research. Moreover, 
the requirements would consume the time of scientists at least in part. This 
they would regard as unnecessary, as these administrative requirements would 
not assist in achieving scientific results. It goes without saying that such ad- 
ministrative burdens could drive competent scientists away from Government- 
sponsored research and could make it difficult, if not impossible, to recruit and 
retain talented young men in scientific research. This, in turn, could jeopardize 
the Government’s medical research program. 
From the standpoint of the Government, the administrative burden required 
by the bill would be enormous and costly. The Commissioner would be required 
to establish elaborate systems for licensing thousands of research workers, for 
inspecting hundreds of laboratory facilities, and for obtaining compliance with 
the bill’s policy. 
In this latter connection, it is noted that the sanctions available to the Com- 
missioner, should he find noncompliance by a Federal agency or private labora- 
tories, are extremely severe inasmuch as all Federal funds for such project would 
be cut off immediately in the ease of a private laboratory, and 30 days after 
notice of violation is served and correction not effected, in the case of a Federal 
agency. 
A further administrative burden would fall on the heads of the Federal grant- 
ing agencies, each of which would have the task of making certain that each 
applicant laboratory for one of its research grants had a current certificate of 
compliance. Since the laboratory would have to apply for a certificate of com- 
pliance before it could obtain Government support for its research project, and 
since the review of such application by the Commissioner would take a signifi- 
cant amount of time, this would inevitably cause delay in initiating the research 
project, a delay which would certainly be wasteful from the standpoint of fur- 
thering needed research. 
The requirement that the Commissioner approve, monitor, license, and inspect 
experiments involving live animals performed by military medical agencies would 
not only result in the above-mentioned unnecessary and unacceptable delays in 
initiating research programs, but could result in increased difficulty in recruit- 
ing competent research personnel and research agencies to work on research 
studies needed by the Armed Forces. 
There are other technical objections, but, in particular, reference is made to 
section 12(g) of the bill which would unqualifiedly require that all animals used 
by students in “practice surgery, or other painful procedures” be “under com- 
plete anesthesia.” In this connection the term “painful” is at best an ambig- 
uous term, and at worst an all-encompassing one. Thus, simple injections ordi- 
narily administered by technicians, are to some extent “painful.” Are such in- 
jections to be outlawed? In respect to the requirement that certain experimental 
animals used by students when subjected to painful procedures shall be “under 
complete anesthesia,” such requirement would, in some cases, negate the value 
of the experiment because of the tissue injuries resulting from such anesthesia. 
Section 2(a) defines animals in such broad strokes as to appear to include 
human beings within it, but nowhere else in the bill is there any indication that 
the bill’s policy extends to human volunteer subjects for experiments. It is 
believed that this issue should be clarified. 
