22 • Alternatives to Animal Use in Research, Testing, and Education 
those of the Organization for Economic Coopera- 
tion and Development, could also be encouraged 
(see ch. 7 and app. E). The costs of agency review 
should be moderate, entailing input from agency 
experts, comment from outside experts, and pub- 
lication. If Federal laboratories were involved in 
the validation of alternative testing methods, ad- 
ditional costs would be incurred. Such a policy 
could encourage industry to develop alternatives 
because the barriers to acceptance would be 
reduced. 
Option 4: Ban procedures for which alternatives 
are available , or give a Federal agency 
authority to ban procedures as valid 
alternatives become available. 
This option recognizes that prohibitions can be 
used to force technological change. Prohibiting 
procedures for which scientifically acceptable 
alternatives are already available would acceler- 
ate the implementation of such alternatives. Ex- 
isting reductions and refinements in animal use 
include the greater use of analgesics in research, 
the use of fewer animals in the LD 50 and Draize 
eye irritancy tests, and reliance on videotaped dem- 
onstrations and computer simulations in edu- 
cation. 
A ban could not only force implementation of 
existing alternatives, but, over time, help focus the 
development of new techniques (as discussed in 
the next section) and allow considerable flexibil- 
ity in achieving the desired end. A disadvantage 
of banning a specified procedure is that the replace- 
ment, or the process of developing one, may be 
even more politically unacceptable (e.g., the in vitro 
culture of human fetal nerve cells). A prohibition 
also takes no account of the question of judging 
the scientific acceptability of an alternative. 
In pursuing this option or the preceding one, 
it is important to appreciate that the swiftest adop- 
tion of alternatives may come about if regulatory 
agencies avoid mandating specific testing require- 
ments. Requiring specified tests might actually 
serve as a strong inhibitor to the implementation 
(and development) of alternative methods. Greater 
flexibility is achieved when testing requirements 
are defined in a manner that allows judgment and 
encourages use of alternate methods. Viewed from 
this perspective, the adoption of alternatives might 
be best stimulated by regulatory requirement for 
evaluation of a potential toxic response, such as 
mutagenicity, rather than requirement of a speci- 
fied test for mutagenicity. 
ISSUE: Should the more rapid development of 
new alternatives in research, testing, or 
education be stimulated? 
Alternatives are currently being developed in 
many phases of animal use. It is worth noting that 
development of many of these techniques, espe- 
cially their validation, cannot occur without ani- 
mals being used (unless humans are used instead). 
In addition, many replacement systems will never 
be fully divorced from animal research and test- 
ing, and therefore they will serve to reduce but 
not eliminate animal use. 
Certain research and testing methods now be- 
ing developed, such as in vitro culture of animal 
components, bear great promise as alternatives. 
Similarly, the growing capabilities of computer 
modeling, for example biological simulation (see 
ch. 6) and pharmacology (see ch. 8), may reduce 
the number of animals needed. Development of 
an enhanced ability to detect and relieve pain can 
help refine animal use. 
Research that spawns alternatives usually takes 
place across traditional disciplinary lines— princi- 
pally within the life sciences— but also in applied 
mathematics, statistics, engineering, physics, and 
chemistry . The principal support for such research 
comes from Federal funds, predominantly NIH and 
the National Science Foundation. In general, there 
is little incentive for private investment in meth- 
odologies at a stage so remote from commerciali- 
zation and, in the case of testing, so governed by 
regulation. Some private concerns, however, spe- 
cifically fund research into alternative testing 
methods (see ch. 12). 
Clearly, research and development require 
money. Determining the optimum level of fund- 
ing, however, and the best way to distribute funds 
remains elusive. Nonetheless, the promotion of 
such research is likely to increase the number of 
alternatives available for implementation; in turn, 
increased implementation is likely to spur research 
in this area. 
Option 1: Take no action. 
If Congress takes no specific steps beyond its 
recent charge to NIH to establish a plan for the 
