HUMANE TREATMENT OF ANIMALS USED IN RESEARCH 307 
Discussion .— No one would put the interpretation here given, on the provision 
quoted. It does not state “only when no other possible methods can be used, 
but only when no other feasible and satisfactory methods can be used.” This 
is a question of impartial scientific judgment. It means that the research sci- 
entist would have to pause to consider whether the experiment could be done 
feasibly and satisfactorily using lower forms of life (there are other lower 
forms besides plants and microbes) and if not, he would have to defend this 
judgment in his project proposal. This is a valid requirement both from a 
humanitarian and scientific point of view. 
NATIONAL SOCIETY FOE MEDICAL RESEAKCH “REASON” NO. 5 
“The proposed Federal regulation of research includes the provision that no 
experiment or test on living animals shall be performed unless a detailed project 
plan is approved by the Secretary of Health, Education, and Welfare. The 
project plan must describe in advance all procedures to be employed with respect 
to living animals. This provision assumes that the investigator knows, in 
advance, each step in his research program. Such is not the case. The general 
objective is known, but the method of attack develops as the work progresses. 
Fruitless avenues are abandoned and new and developing leads followed as they 
open up. Indeed, the entire objective may be abandoned in favor of some newer 
objective that has come into view as the work progresses. The stringent regula- 
tion proposed would stifle real exploratory research and favor more perfunctory 
technological exercises where the outcome is already known in advance.” 
Discussion . — The requirement of a project plan is not appreciably different than 
that already in force for proposals requesting Federal funds for research. It 
should not stifle real exploratory research any more than does the requirement 
now in force. On the contrary, it well might avoid “perfunctory technological 
exercises where the outcome is already known in advance.” Review of grant 
requests by competent scientists tends to avoid waste of Government money on 
unoriginal projects without potential value. 
The proposed legislation will tend to avoid purposeless suffering of animals 
in unplanned or improperly planned experiments. It is true that there may be 
occasions when the extent of animal suffering involved in a project will have to 
be balanced against the scientific worth of the project. This too, is valid, and 
indeed, is one of the main principles of the bill. 
NATIONAL SOCIETY FOR MEDICAL RESEARCH “REASON” NO. 6 
“The proposed law to regulate research demands that records be kept of ex- 
periments, that animals be identified in relation to these experiments, and that 
the disposition of animals also be recorded. Annual reports based on these 
records are to be made in Washington. Presumably the records to be maintained 
and the reports to be made are in addition to the already extensive records 
essential to the collection and reporting of scientific data. It is likely, therefore, 
that these scientifically useless reports would approximately double the burden 
of recordkeeping in conjunction with research. Not only would allocations for 
research be drained away in the employment of extra secretarial help, but also 
in Washington large numbers of clerks would have to read, sort, and file a 
mountain of such useless reports.” 
Discussion . — The records required are, or ought to be already kept by every 
biological scientist. There would be some extra paperwork, in making separate 
reports. This small sacrifice is justified, to implement the purpose of the 
Griffiths bill, a purpose with which few would disagree. 
NATIONAL SOCIETY FOR MEDICAL RESEARCH “REASON” NO. 7 
“The proposed law would authorize the Secretary of Health, Education, and 
Welfare to appoint inspectors with authority to examine the records of individual 
scientists and to stop investigation and destroy the animals if, in the judgment 
of the inspector, the plans outlined in advance had not been followed accurately. 
The inspectors would have great power that could be misused to strangle 
research.” 
Discussion . — There seems to be no reason to assume that inspectors appointed by 
the Secretary of Health, Education, and Welfare would wish to use such power 
as they had, to strangle research. On the contrary, experience with people 
appointed in similar capacity in connection with Federal grants, has led me 
