28 • Alternatives to Animal Use in Research, Testing, and Education 
do not lend themselves to systematic study in hu- 
mans (see ch. 5). 
In testing, procedures like the Draize test and 
the LD 50 are used in part because investigators be- 
lieve that Federal regulatory agencies, such as FDA 
and EPA, require the results of these tests in data 
submissions (see ch. 7). Exercise of oversight au- 
thority could induce Federal regulatory agencies 
to make explicit their disinterest in data derived 
from objectionable tests and to demonstrate their 
ready acceptance of data obtained through alter- 
nate means. Such oversight action, coupled with 
active research into alternative methods, would 
probably end most use of the targeted procedures . 
It is likely that review of protocols by commit- 
tee, particularly a committee with expertise in bio- 
ethics, laboratory animal science, and anesthesia, 
would effectively restrict procedures to those that 
are generally accepted as humane. In both research 
and testing, banning animal use for a specific pur- 
pose would reflect the judgment that knowledge 
gained via that procedure could never justify the 
cost in animal suffering or lives. 
Option 4: Restrict the acquisition of animals from 
particular sources. 
For several decades, States and municipalities 
have wrestled with the issue of the release of dogs 
and cats from pounds to research and educational 
institutions (see ch. 14). Some people feel that the 
release of pound animals for experimentation is 
wrong, because the animals are former pets or 
are too unhealthy to be proper subjects for study . 
In some jurisdictions, research and educational 
institutions are barred from acquiring pound ani- 
mals, while other jurisdictions require that pound 
animals be released to researchers after a certain 
number of days in captivity. 
As pound animals are usually sold at low cost 
(see ch. 11), banning their sale would lead to higher 
procurement costs as the pound animals were re- 
placed with animals that are purposely bred for 
experimentation. (Some animals are already pur- 
pose-bred because certain pound animals are not 
suitable candidates for experimentation.) The pur- 
poseful breeding of such animals for experimen- 
tation in parallel with routine euthanasia of pound 
animals would probably work out to a net increase 
in dogs and cats being killed. 
Option 5: License animal users (e.g., for specified 
uses or for particular kinds of animals). 
Animal users could be granted licenses specify- 
ing the procedures they are authorized to perform 
or the animals with which they may work. Such 
a system' is in place in the United Kingdom under 
the auspices of the Home Office (see ch. 16). Given 
that at least five to six times as many animals are 
used in the United States annually (17 million to 
22 million) as in the United Kingdom (3 million to 
4 million), achieving and maintaining licensure here 
would be a considerably larger and more costly 
enterprise than now exists in any country. 
Implementation of this option would require a 
Federal licensing body with inspection and enforce- 
ment capability. If the British system is the model, 
licenses would be legally enforceable personal doc- 
uments. A license to perform a particular experi- 
ment or a series of experiments or to work with 
a particular species would be nontransferable. 
Confidentiality would be guaranteed in order to 
protect, for example, an investigator’s claim to pri- 
ority in research results. Comprehensive annual 
reporting by licensees and auditing by an over- 
sight body— both integral parts of the British 
system— would be necessary. It is noteworthy that 
in the United Kingdom this system allows every 
animal experiment to be logged (see ch. 16). 
The British system works. It relies heavily on 
a tradition of cooperation between experimenter 
and Home Office inspector. The feasibility of such 
a system in the United States is difficult to predict 
because the dimensions of animal use are so poorly 
characterized. Hence, the number of licensees and 
the resources required for monitoring are un- 
known. Perhaps most important, the extent to 
which the parties involved would cooperate is un- 
certain. 
Option 6: Prohibit the use of animals in research , 
testing, and education. 
No other country and no jurisdiction in the 
United States has completely banned animal use 
in research, testing, or education. In Switzerland, 
a binding referendum of this nature was presented 
to the public for a vote in December 1985, but it 
was defeated (see ch. 16). 
Action to ban animal use fully is the most ex- 
treme of the six options related to the issue of re- 
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