12 HUMANE TREATMENT OF ANIMALS USED IN RESEARCH 
respect to living animals. Research, by its nature, is not completely predictable, 
but proceeds step by step, each step depending on the results of the preceding 
step. Inasmuch as succeeding steps may alter the procedures, nature, and 
purposes of the project at unpredictable intervals, the above requirements 
would result in confusion, delay, frustrations, lack of efficiency, failure to fol- 
low promising leads, and eventual abandonment of many valuable projects. If 
an investigator were to know in advance the detailed steps he was to take, which 
the bill requires him to submit to the Department of Health, Education, and 
Welfare, he would generally be making demonstrations, not pursuing research. 
Sections 4(d) and 4(e) of the bill provide for records to be maintained of all 
experiments 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 indicate the nature of the experiment involved. These recordkeeping require- 
ments proposed to be kept for the Department of Health, Education, and Welfare 
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 unneces- 
sary 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 administra- 
tive 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 Department of Health, Education, 
and Welfare 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, the latter with only the 
limited remedies afforded by the bill. In this latter connection, it is noted 
that the only remedies available to the Secretary of Health, Education, and 
Welfare, should he find noncompliance by a Government instrumentality engaging 
in research, would be a notice which he might give to the head of any Government 
agency which had not theretofore complied with the act, together with subsequent 
public notice of such noncompliance if the deficiency was not corrected within 
30 days of the aforementioned notice to the head of the agency. In the case of 
noncompliance by an individual or institution (as distinct from a Government 
instrumentality) already holding a certificate of compliance, the Secretary of 
Health, Education, and Welfare would be required to send a notice of suspension 
or revocation of such certificate to all agencies which were considering or had 
made a grant to the certificate holder, which procedure would be the only remedy 
available. It is not clear what the consequences would be if a grantor agency 
disagreed or disregarded the Secretary of Health, Education, and Welfare’s 
notice, or substituted an award of a research contract covering the same research 
project in lieu of a revoked grant. In view of the limited remedies available 
even if noncompliance should be found, the wisdom of establishing elaborate 
administrative machinery to implement such program is open to question. 
A further administrative burden would fall on the heads of the Federal 
granting agencies which would have the task of making certain that each ap- 
plicant for one of its research grants had a current certificate of compliance. 
Since the researcher would have to apply for a certificate of compliance before 
he could obtain Government support for his research project, and since the De- 
partment of Health, Education, and Welfare review of such application would 
take a significant amount of time, this would inevitably cause delay in initiat- 
ing the research project, a delay which would certainly be wasteful from the 
standpoint of furthering needed research. 
The requirement that the Department of Health, Education, and Welfare ap- 
prove, monitor, license, and inspect experiments involving live animals per- 
formed by military medical agencies would not only result in the above-mentioned 
unnecessary and unacceptable delays in initiating research programs, but would 
result in increased difficulty in recruiting 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 4(f) 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 ambiguous 
