8 HUMANE TREATMENT OF ANIMALS USED IN RESEARCH 
specified a longer period during which animals must be kept alive for essential 
purposes of an experiment or test, animals which are seriously injured as a 
result of the experiment would be required, under the bill, to be killed painlessly 
immediately after the conclusion of the operation inflicting the injury. 
The bill would authorize the Secretary to suspend or revoke any certificate 
of compliance or license for failure to comply with any provision of the bill. 
No grant, or payment under a grant, could be made to any person whose cer- 
tificate has been suspended or revoked “to the extent that the Secretary’s order 
shall provide for the purpose of obtaining compliance with this act.” The notice 
of revocation or suspension would be required to state a time within which the 
holder could apply for reinstatement. 
The bill would also provide that if the Secretary determines that any agency 
or instrumentality of the United States has not complied with the requirements of 
the bill, the Secretary would notify the head of such agency and if noncompliance 
is not corrected within 30 days after notice is served, the Secretary would be 
required to give public notice of the violation. 
This Department is in agreement with the principle that laboratory animals 
should receive humane treatment. In our opinion, however, the proposed system 
of Federal regulation based on the requirement of certificates and licenses is 
neither a desirable nor a feasible approach to the achievement of the stated 
objective of the bill and, furthermore, could seriously impede and obstruct the 
successful conduct of research programs which utilize animals. 
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 con- 
stitute 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 experiments. However, 
the annual reports required in this bill would be in addition 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 Department could 
hamper or delay the scientist in following up new research leads. Many of the 
significant discoveries of the past wei’e 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 following 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 assure its approval by the Department 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 the abandonment of the pursuit of research leads at the time most pro- 
pitious for the discovery of new knowledge. 
Administration of H.R. 1937 would impose a difficult and costly task on the 
Department. The project plans and annual reports which would be required to 
be filed 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. 
Moreover, the role of the Department in monitoring and evaluating the com- 
pliance of other Federal agencies also presents a serious problem. Under the 
bill, the Secretary would be authorized to notify the head of any agency or 
instrumentality of the United States of noncompliance with this act, and if satis- 
factory correction is not made within 30 days, to make public notice of such 
noncompliance. 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 some of the standards and criteria for humane treatment of animals 
included in the provisions of the bill might be accepted as adequate general 
statements of desirable conditions or objectives, as criteria for the issuance of 
licenses and certificates, which in turn are the prerequisites to the award of a 
Federal research grant or the conduct of Federal research, they would present 
serious problems of definition and enforcement. 
