286 • Alternatives to Animal Use in Research, Testing, and Education 
• provide guidelines and consultation to re- 
search personnel regarding type and amount 
of the three classes of drugs recommended 
as being appropriate for each species of ani- 
mal, through the animal care committee or 
attending veterinarian; and 
• assure that the use of the three classes of drugs 
effectively minimizes the pain and discomfort 
of the animals while under experimentation 
[9 CFR 3.10, 3.34, 3.59, 3.84, 3.110, 3.134]. 
Few petitions for changes in existing regulations 
have been made. No person or organization has 
used the formal rulemaking process to seek to add 
any classes of warm-blooded animals. In 1982, the 
Humane Society of the United States filed a peti- 
tion for rulemaking and collateral relief that, 
among other things, sought definitions of the terms 
"pain,” "distress,” and "routine procedures” and 
a requirement that research facilities explain in 
adequate detail why pain-relieving drugs are with- 
held from animals used in experiments acknowl- 
edged to cause pain and distress (12). 
In summary, USDA’s approach has been literal 
and cautious with regard to research facilities. This 
position can be traced to two influences . First, both 
the act itself and its legislative history make clear 
Congress' desire to avoid any entanglement in the 
actual conduct of research. Second, both the legis- 
lative and executive commitments of funds and 
personnel for enforcement have never lived up 
to the expectations of those who believe the pri- 
mary mission of the existing law to be the preven- 
tion or alleviation of experimental-animal suffering. 
Enforcement 
The responsibilities of APHIS in enforcing the 
Animal Welfare Act fall into three main categories : 
• making, implementing, and enforcing policies 
and rules for national and international pro- 
grams to protect the health of U.S. livestock 
and poultry resources, assuring quality and 
safety of veterinary biologies, and providing 
for the welfare and humane treatment of cer- 
tain animals; 
• cooperating and providing technical assistance 
to State and local governments regarding in- 
ternational quarantines and exotic animal dis- 
ease programs; and 
• providing professional development and train- 
ing for APHIS personnel and training for for- 
eign visitors in veterinary service programs. 
Nineteen public laws outline APHIS’S duties in 
the first area, including the Animal Welfare Act, 
the Horse Protection Act, and the Twenty-Eight 
Hour Law (49 FR 26674). By far, the most time- 
and resource-consuming APHIS objective is pro- 
tecting domestic plants and livestock from diseases 
and pests . Of 841 pages in the Code of Federal Reg- 
ulations on APHIS duties and programs, only 100 
are devoted to animal welfare activities under the 
relevant acts (7CFR 1984 ed. 371.2). Port -of -entry 
inspections by APHIS seek to prevent the introduc- 
tion of insects, plant diseases, nematodes, and ani- 
mal pests and diseases harmful to crops and crop 
products. Plant exports are controlled through a 
certification system administered by .APHIS, and 
cooperative programs with States are conducted 
to eradicate domestically established plant pests. 
The APHIS mission, then, is traditionally bound 
to certification, inspection, and cooperative assis- 
tance programs that govern agricultural activities, 
devoted almost exclusively to protecting plants and 
animals used to produce food and fiber. 
The APHIS Assistant Deputy Administrator for 
Animal Health Programs, under the Deputy Ad- 
ministrator for Veterinary Services, is responsi- 
ble for directing enforcement activities through 
four regional offices, located in Scotia, NY; Tampa, 
FL; Englewood, CO; and Fort Worth, TX (50 FR 
31341). (Prior to 1985, five regional offices existed 
but this was changed in response to a review of 
APHIS activities by the General Accounting Office 
(GAO).) Licensing, registration, and inspection of 
all regulated entities— dealers, exhibitors, research 
facilities, carriers, intermediate handlers, and auc- 
tion sales— are handled by a field force directed 
by Veterinarians-in-Charge in the APHIS offices 
in 45 State capitals. Field officials conducting ani- 
mal welfare work include veterinary medical offic- 
ers, compliance officers, and animal technicians. 
Six veterinarians trained in laboratory -animal hus- 
bandry procedures coordinate animal welfare ac- 
tivities among the four regions (43). APHIS has 286 
Veterinary Medical Officers (inspectors), who 
spend approximately 6 percent of their time in- 
specting research facilities (25). 
