352 HUMANE TREATMENT OF ANIMALS USED IN RESEARCH 
the annual report, and “such additional reports or information as the Secretary 
may require” to be set by the Secretary. Anyone who has worked with Govern- 
ment forms knows that they are made up to include every conceivably useful 
detail and tend to enlarge and proliferate rather than the reverse. The facts 
are that project plans are already on file with each agency before funds are 
granted, that no agency is forced to give funds to what it considers to be 
ill-conceived, unnecessary, or cruel experiments, and that applications have been 
turned down on the basis that the experimental design was not as humane as it 
should be. Therefore Government and private agencies already have, and are 
exercising, the right to see that research money goes only to competent scientists 
with adequate facilities, including animal care facilities, for the research they 
propose to do. 
The provision that representatives of the Secretary, with unspecified training, 
could destroy experimental animals with no chance for appeal could endanger 
costly long-term experiments if the representatives were not in a position to 
evaluate the techniques being used against the information to be gained. It is 
hard to imagine that highly trained individuals would care to make a lifetime 
profession of such inspection chores, and it might be relatively simple for a 
person opposed to animal research tO' obtain such an inspector’s position and 
arbitrarily terminate significant work. 
Finally, the definition of “person” to include “institutions” and “organizations” 
would lead to considerable confusion, if not to real detriment to research. It 
could result in the suspension of all federally supported research at a large 
university, for example, if a single individual failed to comply with some 
provision of the act. 
The Moulder bill contains a number of provisions which, while sounding good 
from the outside, are completely unrealistic. 
First, the definitions lead to a variety of interpretations. There could be a 
real difference of opinion as to which lower animals are capable of developing a 
conditional response, “stress” as defined would include the taming or training 
of an animal, and “laboratory” can mean both an institution and a group ox- 
person within that institution. 
Second, the list of fields in which an applicant for qualification may be trained 
does not include biochemistry, pharmacology, or microbiology; yet these are all 
fields of exceedingly productive research, including much of the research on 
cancer, which involve the use of experimental animals. 
Third, the Commissioner of Laboratory Animal Control, designated by the bill 
to supervise the regulatory program, is required not to have had any experience 
with, or direct knowledge, of, medical research, through the provision that he 
shall never have been connected with any laboratory. This insures that the 
Commissioner shall have the least possible background for the job he is to do. 
Indeed, under the broad definition of “laboratory” used in the bill, the Commis- 
sioner cannot even have been connected with, or graduated from, a school where 
animal research was carried on. 
Fourth, the provision that “anesthetics shall be administered only by licensed 
veterinarian or a doctor of medicine qualified in anesthesiology” would require 
that each investigator have the services of a veterinarian or anesthesiologist 
available at the start of each acute experiment. It would mean that a doctor 
of medicine without specialized training in anesthesiology would not be allowed 
to administer any anesthetics to animals, though he might do so to human beings. 
Finally, the provision that all project plans be made available for public 
inspection, study, and copy might discourage people with really new ideas for 
which they wished to receive credit from publishing their plans in such a way 
before they could be tested, or might lead to the submission of vaguely worded 
or actually misleading project plans in order to preserve secrecy in areas where 
competition for new discoveries is keen. 
This bill is frankly antagonistic to medical research and, while having the 
appearance of allowing such research to proceed, could be used to bring it to a 
virtual standstill. We believe that the Congress, which is presently supplying 
funds for vast research programs in a number of health sciences, does not want 
this to happen. 
