392 • Alternatives to Animal Use in Research, Testing, and Education 
approval of funding (9). The committee must ask the 
following questions for each experiment (12): 
• Will the minimum possible number of animals be 
used? 
• Is the use of animals necessary in this experiment? 
• Are provisions for care of these animals adequate? 
Different compliance with these policies is needed 
for intramural versus extramural research. For NASA 
facilities, ACUC reports are required to be sent to the 
Director of the Life Sciences Division at NASA head- 
quarters reviewing facility procedures. AAALAC accred- 
itation is required for all NASA installations. Currently 
all facilities are moving toward AAALAC accreditation 
but have not yet obtained it (12). For extramural re- 
search, the institution must submit a written assurance 
that its animal care policies are equivalent to the NASA 
policy. (AAALAC accreditation is one way of showing 
compliance.) Noncompliance will result in termination 
of the research by the ACUC and possibly sanctions 
after review by the Director of the Life Sciences Divi- 
sion (19). 
The Ames Research Center (Moffett Field, CA), NASA’s 
primary center for nonhuman research, illustrates the 
implementation of NASA policy. The Ames Research 
Center has established the Animal Users Guide for 
Ames -sponsored laboratory experiments using animals. 
This guide sets up two entities to ensure that all legal 
requirements are met: The animal care facility is re- 
sponsible for housing and maintaining the animals prop- 
erly, and the animal care and use committee must mon- 
itor all animal care and experimentation progress at 
the center. In addition, the guide states (28): 
EVERY RESEARCH SCIENTIST AND ALL RESEARCH 
PERSONNEL, CONTRACTORS, AND GRANTEES ARE 
RESPONSIBLE FOR OBSERVING THE LEGAL REQUIRE- 
MENTS CONCERNING LABORATORY ANIMALS. 
The Ames committee reports to the center’s Direc- 
tor of Life Sciences and is responsible for: 
• reviewing the use of animals in proposed and on- 
going experiments; 
• reviewing all animal experimentation performed 
by contractors or grantees; 
• serving as an advisory committee on all questions 
of animal care and use, and as a forum for resolv- 
ing differences that may occur; and 
• reviewing animal-related inventions and devices 
(28), 
At present, the Ames committee has 10 members— 4 
non-NASA, non-life-sciences laypersons; 1 veterinarian; 
1 scientist -veterinarian; 1 engineer; 2 scientists; and 1 
science manager. In addition, 2 veterinarians accred- 
ited in Laboratory Animal Medicine are advisors. The 
lay members include an attorney, a professor of relig- 
ion (ethics), the chairman of the Department of Educa- 
tion at a local college, and the public relations director 
of the Santa Clara Valley Humane Society. This is one 
of the few such committees in the country with a 40 
percent lay membership. According to the Acting Di- 
rector of Life Sciences at Ames Research Center, "the 
out -of -house members have contributed materially to 
the [committeel.” Two of the lay members head sub- 
committees that are reviewing and updating the Ani- 
mal Users Guide and committee charter and develop- 
ing an animal user’s orientation program (14). 
National Science Foundation 
A summary of the animal care requirements of the 
National Science Foundation (NSF) is found in Section 
713 of the NSF Grant Policy Manual (30) and included 
in the NSF document "Grant General Conditions,’’ that 
is sent to each grantee when an award is made. Any 
grantee performing research on warm-blooded animals 
must comply with the Animal Welfare Act and its reg- 
ulations and follow the NIH Guide. NSF has no formal 
inspection system to check on compliance with these 
policies, as that is judged to be the responsibility of 
USDA/APHIS (8). The result is a voluntary adherence 
system by NSF grantees. 
Beginning in 1986, NSF imposed two new require- 
ments on grant applicants and grantees who perform 
research on vertebrate animals: 
• Each proposal must be reviewed by an institutional 
animal care and use committee. 
• Each proposal must be accompanied by a statement 
from the grantee that assures the grantee’s com- 
pliance with the PHS policy. 
Grant proposals submitted to NSF thus face three sep- 
arate reviews— one by the grantee’s institutional com- 
mittee, one by outside reviewers, and one by NSF staff. 
Although these are primarily scientific in nature, 
reviewers are asked to comment on animal welfare is- 
sues. If a proposal involves the use of animals, suffi- 
cient information must be provided to allow evalua- 
tion of the appropriateness of experimental protocols 
with respect to the choice of species, the number of 
animals to be used, and any necessary exposure of ani- 
mals to discomfort, pain, or injury (29). With this infor- 
mation, the reviewers are asked to (29): 
. . . comment if you have any concerns regarding the 
violation of animal welfare laws or guidelines, the ex- 
posure of animals to unnecessary pain or mistreatment, 
or the use of excessive numbers of animals. If the spe- 
cies being used is not the one most appropriate, or if 
alternative or adjunct methods could be used to elimi- 
nate or reduce the need for animal experimentation, 
please comment. 
Veterans' Administration 
The Veterans’ Administration is unique in its policies 
governing humane treatment and appropriate veteri- 
