30 • Alternatives to Animal Use in Research, Testing, and Education 
data on animal use are put, maintaining the status 
quo may be adequate, an unnecessary expense, 
or not nearly enough. 
Option 2: Eliminate the APHIS reporting system. 
If the value of the information obtained by the 
APHIS system is not justified by the money allo- 
cated for its collection, the APHIS reporting sys- 
tem could be terminated. In adopting this option, 
Congress would signal a willingness to rely on esti- 
mates produced by nongovernment organizations 
and individuals without the benefit of reports or 
inspections. 
Option 3: Correct inadequacies in the present 
APHIS system of reporting use of ani- 
mals mandated by the Animal Welfare 
Act. 
To gain a more accurate picture of the use of 
nonhuman primates, dogs, cats, rabbits, guinea 
pigs, and hamsters in the United States, oversight 
authority could be used to require that APHIS alter 
its present practices in one or more of the follow- 
ing ways: 
• correct its reporting form to eliminate am- 
biguities; 
• change the reporting deadline or publication 
schedule for the annual Animal Welfare En- 
forcement Report , so that fewer institutional 
reports are excluded; 
• audit or spot -check the "Annual Report of Re- 
search Facility” forms and facilities; 
• strictly enforce the regulation requiring that 
all institutions within the United States using 
mandated species register with APHIS and 
complete the "Annual Report of Research Fa- 
cility” forms as required by law; or 
• allocate more of APHIS ' resources for enforce- 
ment of the Animal Welfare Act to reporting. 
These changes would require little additional 
government funding or expenditure by regulated 
entities, although it could affect how they allocate 
their resources. Adoption of this option would 
bring APHIS closer to delivering the information 
it is obliged to deliver under the Animal Welfare 
Act. 
Option 4: Alter the APHIS system to count addi- 
tional kinds of animals (eg., rats and 
mice). 
Rats and mice account for approximately 75 per- 
cent of the animals used in research, testing, and 
education in the United States. They go uncounted 
because a USDA regulation under the Animal Wel- 
fare Act excludes them from its definition of ani- 
mals. There is, however, some voluntary report- 
ing of the use of these species on the APHIS “Annual 
Report of Research Facility” forms. 
Data on rats and mice (or other currently un- 
regulated animals) could be obtained in either of 
two ways. Congressional oversight of the Secre- 
tary of Agriculture could lead to a requirement 
that the use of rats and mice be reported. This 
would require additional funding for APHIS, be- 
cause the number of facilities under the act’s reg- 
ulations would increase. On the other hand, the 
counting mechanism is already in place, and only 
minor changes would be needed. 
Expanding the APHIS animal counting require- 
ment to include rats and mice would raise costs 
for some members of the research and testing com- 
munities. Accurate counting of these species, in- 
cluding categorization of experiments for pain and 
pain relief, is a labor-intensive activity and hence 
costly. Such costs will be of exceptional concern 
to institutions using large numbers of rats and 
mice, and these users can be expected to question 
whether accounting needs for policy evaluation 
require the extra expense. 
A broadening of the APHIS census to include rats 
and mice would still leave some uncounted. The 
Animal Welfare Act’s definition of research facil- 
ity covers any institution that uses primates, dogs, 
cats, rabbits, guinea pigs, hamsters, or other warm- 
blooded animals, as the Secretary of Agriculture 
may determine are used in experimentation,. and 
that either purchases or transports animals in com- 
merce or receives Federal funds for experiments. 
Thus, a facility that breeds all its animals in- 
house— most likely rats or mice— falls outside the 
scope of the Animal Welfare Act and accompany- 
ing USDA regulations. The number of facilities 
breeding and using rats and/or mice exclusively 
is unknown. Some toxicological testing laboratories 
are likely to fall into this group. 
Option 5: Establish an independent census of ani- 
mal use, either on a one-time or peri- 
odic basis. 
