294 • Alternatives to Animal Use in Research, Testing, and Education 
ing an animal facility's compliance duties comes 
from a study commissioned by EPA to estimate 
the compliance costs for its new GLPs . That study 
concluded that additional costs to industrial lab- 
oratories would be $15 million ($80,000 per lab- 
oratory for 185 laboratories) (48 FR 53946). 
Military Research and Training 
In 1973, Congress prohibited the use of dogs for 
research and development of chemical or biologi- 
cal weapons (Public Law 93-365). At that time, Sen- 
ate and House conferees stated that they did not 
support the use of dogs for research on chemical 
or biological agents whose only function was to 
destroy life. They believed it essential, however, 
that research to improve and save human and ani- 
mal lives be continued, including establishing im- 
munologic levels, occupational safety hazard levels, 
and other “vital medical research designed to im- 
prove and save lives.” 
Continued concern about this issue prompted 
a request for a GAO investigation of the U.S. Army’s 
Edgewood Arsenal (Edgewood, NJ). The Comptrol- 
ler General reported that the Army had complied 
with the restriction in fiscal year 1975 and, fur- 
ther, that compliance would continue. He re- 
sponded to congressional concern about APHIS’S 
lack of jurisdiction to inspect Federal facilities with 
the finding that, although dogs being used in toxic 
exposure research were treated well during ex- 
perimental procedures, their housing facilities 
were deficient and needed physical improvements. 
He stated that legislation would be required to ac- 
complish that purpose (33). Meanwhile, to imple- 
ment the new restrictions, the Secretary of De- 
fense issued three policy documents, in 1976 (44), 
1982 (46), and 1984 (44), defining the types of in- 
vestigations in which animals could be used. 
In 1983, publicity about the use of dogs and pigs 
at the Uniformed Services University of Health Sci- 
ences (Bethesda, MD) to train military surgeons 
to treat wounds led to prohibitions on the expend- 
iture of Department of Defense (DOD) funds in 
fiscal years 1984 and 1985 (Public Law 98-473) for 
the training of surgical personnel in treating 
weapon -produced wounds in dogs and cats (26). 
The Assistant Secretary of Defense for Health Af- 
fairs issued a memorandum in 1984 that explained 
the reach of the new limitation and superseded 
old policy directives (45): 
. . . effective October 1, 1983, dogs or cats will 
not be purchased or otherwise used for the pur- 
pose of training Department of Defense students 
or other personnel in surgical or other medical 
treatment of wounds produced by any type of 
weapon. In addition, the standards of such train- 
ing with respect to the treatment of animals shall 
adhere to the Federal Animal Welfare Law and 
to those prevailing in the civilian medical com- 
munity. 
Current DOD policies and their effect on intra- 
mural and extramural defense research are ex- 
amined in more detail in appendix B. 
Animal welfare groups have expressed dissatis- 
faction about substitution of other animals for dogs 
and cats in ballistics training, and pressure on Con- 
gress to prohibit animals’ use in this type of re- 
search is expected to continue (15). 
Endangered Species, Public Health, 
and Import Legislation 
Research facilities that plan to import, take, or 
otherwise use nonhuman primates or other ani- 
mals protected by national or international laws 
and agreements must comply with provisions 
found in several laws. Besides prohibiting or con- 
trolling acquisition of some types of animals, these 
laws and agreements generally require, at a mini- 
mum, a permit or authorization from one or more 
Federal agencies. Relevant legislation includes: 
• Section 7 of the Endangered Species Act of 
1973, as amended (16 U.S.C. 1531 et seq.), and 
regulations administered by the Research Di- 
vision of the Fish and Wildlife Service [50 CFR 
10-241; 
• Public Health Service Act regulations govern- 
ing importation of nonhuman primates, both 
to control the spread of animal-borne disease 
(42 U.S.C. 264; 42 CFR 71) and for use in pro- 
ducing and testing viral vaccines (42 U.S.C. 
262; 21 CFR 620 et seq.); 
• the Airline Deregulation Act of 1978 and the 
Tariff Schedules of the Civil Aeronautics Board; 
• Convention on International Trade in Endan- 
gered Species of Wild Fauna and Flora Treaty 
of 1973 (see app. E); and 
• certificates of need for importing rhesus mon- 
keys (a 1955 agreement between the United 
States and India, resulting in the Indian Rhe- 
sus Monkey Certification Program). 
