HUMANE TREATMENT OF ANIMALS USED IN RESEARCH 17 
The volume of paperwork that would be imposed on research investigators 
by the system of project plans and annual reports proposed in the bill would 
constitute a serious burden on the time and creative energies of research 
scientists engaged in the programs in question. Good research investigators 
keep careful records of their animals as part of the protocol of their experi- 
ments. However, the annual reports here required in this bill would be in addi- 
tion to the report of scientific achievements which the scientist would ordinarily 
write at the end of his experiment. Since many millions of animals are used 
each year in the conduct of medical research and testing in the United States 
the total sum of this reporting load on the scientific investigators would be 
very great. 
Moreover, the necessity of filing a project plan with the Commissioner could 
hamper or delay the scientist in following up new research leads. Many of 
the significant discoveries of the past were unexpected byproducts of research, 
suggested by leads noticed in the course of quite another line of research. The 
effective pursuit of scientific knowledge requires that the scientist not only 
be permitted, but encouraged, to follow promising new leads. The bill would 
require the scientist who wishes to pursue a new lead to interrupt his work 
to file a project plan and await its approval by the Commissioner before he 
could undertake any use of animals. We have consistently protected and 
promoted the freedom of scientists to follow new research leads, for it is the 
unexpected and unpredictable discovery which often results in new and valuable 
scientific knowledge, and we would oppose a provision which would cause the 
delay or even abandonment of the pursuit of research leads at the time most 
propitious for the discovery of new knowledge. 
Administration of H.R. 3556 would impose a difficult and costly task on the 
proposed Agency for Laboratory Animal Control. The project plans and 
annual reports which would be required to be filed with the Commissioner by 
each investigator would constitute a great volume of paperwork. A large staff 
concerned with the analysis of specific proposals and an inspection service 
would be necessary to provide compliance with the bill’s provisions. Few 
scientists qualified to evaluate the use of animals in the context of the total 
research project would be interested in engaging in such regulatory and policing 
activities. 
Moreover, thhe role of the Agency in monitoring and evaluating the compliance 
of other Federal agencies also presents a serious problem. Under the bill, the 
Commissioner would have the obligation to make determinations as to the degree 
of compliance of other Federal agencies and would be required to give public 
notice of any noncompliance, and “no funds may thereafter be used by the non- 
complying agency or instrumentality for experiments or tests involving the use 
of animals.” It is difficult to see how such an interagency relationship could be 
developed to the satisfaction of either the administering agency or those whose 
practices would be monitored and evaluated. 
While many of the standards and criteria for humane treatment of animals 
included in the provisions of the bill could be accepted as adequate general state- 
ments of desirable conditions or objectives, as criteria for the issuance of li- 
censes and certificates, which in turn are the prerequisites to the award of Fed- 
eral research grants or the conduct of Federal research, they would present 
serious problems of definition and enforcement. 
Finally, it should be noted that public and private groups are currently work- 
ing to solve problems in this field. We will continue to support such efforts to 
foster and promote policies and practices designed to assure humane treatment 
of animals. Further, we in this Department will make every effort to conduct 
our own research activities in accordance with reasonable standards and to pro- 
mote the adoption of such standards by recipients of our research grants. 
In view of our fundamental disagreement with the approach and principal 
features of the bill, as indicated above, we have not mentioned in this memoran- 
dum a number of other ambiguities and objectionable provisions in the bill, for 
the clarification or improvement of these provisions would not alter our oppo- 
sition to its enactment. 
