App. B— Regulation of Animal Use Within Federal Departments and Agencies • 387 
3216.1, issued by the Deputy Secretary of Defense in 
1982. This statement sets policy on the humane treat- 
ment and appropriate care of animals used in research 
and the responsibilities of different DOD personnel to 
carry out the directive. In general, it follows the Ani- 
mal Welfare Act and the NIH Guide , along with attempt- 
ing to incorporate alternatives to animal use in the form 
of replacement, reduction, and refinement. Other, spe- 
cial policies treat the general use of nonhuman primates 
and prohibit the use of dogs, cats, and nonhuman pri- 
mates for developing nuclear weapons. The directive 
also requires that all proposals or designs for animal 
experiments undergo appropriate animal welfare re- 
view to confirm: “1) the need to perform the experi- 
ment or demonstration; 2) the adequacy of the design 
of the experiment or demonstration; and 3) compliance 
with established policy on the use of animals” (20). 
Army Regulation 70-18 (a Joint Service regulation) 
implements the directive's policies uniformly for all 
DOD components. The authority for enforcing this reg- 
ulation is conferred to the Secretary of the Army, who 
is required to develop and issue, in consultation with 
the other DOD components, regulations implementing 
the directive. Army Regulation 70-18 states that all DOD 
facilities using animals should seek AAALAC accredi- 
tation. Also, it sets up a long chain of responsibilities 
for establishing and policing animal welfare policies. 
The regulation states that the Under Secretary of De- 
fense for Research and Engineering will: "1) issue pol- 
icies and procedural guidance under DOD directive 
3216.1, 2) allocate nonhuman primate resources, and 
3) designate a veterinarian as the DOD representative 
to IRAC [Interagency Research Animal Committee]” (21). 
The Surgeon General of each DOD component involved 
in animal research must supervise animal use and im- 
plement this regulation in each component, establish 
a joint working group to identify and conserve non- 
human primate resources, and establish and provide 
representatives to a joint technical working group that 
periodically reviews the care and use of animals in DOD 
programs. Finally, the local commander of a facility 
must ensure that: 
• all programs involving animals conform to the 
guidelines cited in Army Regulation 70-18; 
• local animal care and use, procurement, and trans- 
portation policies and procedures comply with the 
regulation; 
• animals used or intended to be used will experi- 
ence no unnecessary pain, suffering, or stress, and 
their use will meet valid DOD requirements; 
• alternatives to animal species will be used if they 
produce scientifically satisfactory results; and 
• dogs, cats, or nonhuman primates are not used in 
research conducted to develop nuclear, biological, 
or chemical weapons (21). 
Thus, the powers and responsibilities for carrying out 
DOD animal welfare policies are decentralized. DOD 
does not do any inspections of its facilities. The facil- 
ities are required to submit annual reports to USDA 
under the regulations implementing the Animal Wel- 
fare Act. 
The Army regulation builds the institutional review 
structure around the local animal care committee. Lo- 
cal commanders must form a committee to oversee the 
care and use of animals in their facilities. The commit- 
tee must have at least three members, including at least 
one person not involved in the proposed project and 
one veterinarian. The committee reviews: 1) all aspects 
of animal care to ensure that established policies, stand- 
ards, and regulations are complied with; and 2) all 
research protocols and proposals for proper animal wel- 
fare policies and good animal experimentation stand- 
ards. Sufficient information to do this animal care and 
treatment review must be presented with all research 
proposals. In addition, proposals that involve experi- 
mentation on nonhuman primates are reviewed sepa- 
rately by the proper DOD component office (21). 
As with other departments in the Federal Govern- 
ment, DOD contracts with outside investigators for 
some of its research. The DOD extramural animal re- 
search policy requires that the same standards outlined 
in Army Regulation 70-18 be followed by contractors 
in order to receive DOD funds. Assurance is obtained 
by written statements from the recipient’s animal care 
committee or other responsible official. An assurance 
is also required that the proposal or protocol has been 
reviewed and approved by the local animal care and 
use committee or by the attending veterinarian (21). 
Enforcement of these policies for extramural research 
is more difficult than the intramural policy, since in- 
vestigators and administrators are not directly respon- 
sible to the military line of command. 
In addition to DOD -wide policies issued by the Office 
of the Secretary, a recommendation is pending in the 
Army Medical Research and Development Command 
that an Advisory Committee on Animal Welfare be ap- 
pointed, including non -DOD representatives, to meet 
periodically about concerns related to the use of ani- 
mals for research and training purposes (7). 
In 1983, the Air Force commissioned an outside re- 
view panel to study animal use in its Aerospace Medi- 
cal Division. The panel looked at Brooks Air Force Base 
(San Antonio, TX) and Wright -Patterson Air Force Base 
(Dayton, OH), which together account for 95 percent 
of the service's animal use. The panel found the cur- 
rent policy in place to be satisfactory and was (17): 
. . . impressed with the thoroughness and genuine con- 
cern of all those involved to ensure that appropriate 
measures are taken to effect proper care and use of 
animals. Furthermore, there was a clear emphasis on 
selection of alternatives to animal use where feasible. 
Excellent progress was shown in the use of simulation 
models for a variety of radiation and toxicological 
studies. 
