32 • Alternatives to Animal Use in Research, Testing, and Education 
Setting minimum standards would still give each 
agency and department the flexibility to tailor spe- 
cific policies to unique situations, yet it would estab- 
lish a Federal model for standards of animal care 
in experimentation and ensure humane proce- 
dures in Federal facilities. 
A Federal intramural policy might incorporate 
policies and procedures that address facility ac- 
creditation and institutional review of research 
proposals. A composite, minimum Federal policy 
could reflect the most progressive parts of vari- 
ous current agency standards. 
It is noteworthy that this type of action has been 
taken to protect human research subjects. A Model 
Federal Policy for the Protection of Human Re- 
search Subjects involved in research conducted, 
supported, or regulated by Federal departments 
or agencies is now in draft form. The policy will 
be implemented through routine policy and pro- 
cedural channels of the departments and agencies. 
The advantage of minimum standards is that all 
concerned parties know the policy and can im- 
mediately and permanently put in place the appro- 
priate organizational structure and facilities to 
guarantee adherence. 
ISSUE: Should the Animal Welfare Act of 1966 
be further amended; or its enforcement 
enhanced? 
One criticism of the Animal Welfare Act is the 
lack of coverage of practices other than anesthe- 
sia and analgesia during actual experimentation. 
Although the most recent amendments to the act, 
in 1985, direct institutional animal committees to 
assess practices in experimentation and require 
that professionally acceptable standards are fol- 
lowed during experimentation, the act at the same 
time forbids any regulation related to the design 
or performance of experiments. Additional com- 
plaints concern the adequacy of resources for its 
enforcement, the enforcement structure, the 
choice of APHIS as the primary enforcement 
agency, and the cumbersome recordkeeping. 
In considering whether the act should be strength- 
ened, some related issues must be kept in mind. 
First, a change in authority may require funding 
for implementation and enforcement. Second, any 
change must take into account the present re- 
sources of those affected and their ability to achieve 
compliance without compromising other objec- 
tives. Thus, an important consideration is whether 
or not regulated institutions have sufficient institu- 
tional and independent veterinary resources to ef- 
fect meaningful compliance with a strengthened 
law and still meet their testing or research objec- 
tives. Finally, strengthening the Animal Welfare 
Act in the face of differences within the scientific 
and animal welfare communities will carry con- 
siderable symbolic value. 
Option 1: Take no action. 
By maintaining the status quo, Congress would 
give a strong signal to all concerned parties that 
it is satisfied with the present regulatory structure 
for animal use in the United States and that no 
change is deemed necessary. More specifically, 
selection of this option would imply that current 
enforcement efforts are sufficient and that it is 
not necessary to regulate rats and mice used in 
experimentation . 
Option 2: Eliminate funding for enforcement of 
the Animal Welfare Act. 
Elimination of funding for enforcement of the 
Animal Welfare Act by APHIS would save the Fed- 
eral Government approximately $5 million annu- 
ally. Without these funds, there would be no in- 
spections of facilities (including exhibitors, dealers, 
and research institutions) using nonhuman pri- 
mates, dogs, cats, rabbits, guinea pigs, or hamsters 
and no annual census of these six kinds of animals. 
Action taken by APHIS against violators would 
cease. Therefore, the objective of the Animal Wel- 
fare Act— to safeguard the humane care and treat- 
ment of certain animals— would no longer be met. 
Option 3: Increase funding for enforcement of the 
Animal Welfare Act. 
Increased funding for the enforcement of the 
Animal Welfare Act would bolster enforcement 
of the present law. Additional funds could be used 
to: 
• increase the training of inspectors; 
• increase the number of enforcement agents 
in the field, so as to raise the number of in- 
spections; 
• oversee consistent interpretation of existing 
regulation by inspection and enforcement 
agents in the field; and/or 
