App. B— Regulation of Animal Use Within Federal Departments and Agencies • 393 
nary care for laboratory animals because it has required 
all its facilities using animals to seek and obtain AAALAC 
accreditation (see ch. 15). This policy was originated 
in 1971, and 81 out of 174 VA facilities (as of Apr. 1, 
1985) had some level of AAALAC accreditation. Not all 
VA constituents apply for accreditation, since some do 
not engage in animal research. In fact, the VA has a 
contract with AAALAC covering all its research facil- 
ities that prohibits failure of accreditation of any con- 
stituent facility solely for financial reasons (10). 
In addition to requiring adherence to the PHS policy, 
the VA has a lengthy research review process with a 
strong committee structure. At the local research fa- 
cility, each research and development committee has 
a subcommittee for animal studies that oversees all such 
research. The membership varies, though it includes 
at least one member of the research and development 
committee, a Veterinary Medical Officer (VA employee), 
and two to four investigators who are involved in 
studies using animals. Thus, there are no laypersons 
or persons not affiliated with the research facility on 
the subcommittee. Except for the veterinarian, who 
serves indefinitely, members serve 3-year terms (31). 
The subcommittee has three primary functions: 
• to approve the use or uses made of animal sub- 
jects in all research studies as they relate to animal 
welfare laws, regulations, and policies; 
• to review all animal studies for need, adequacy, 
and availability of essential animal research facil- 
ity support; for the appropriateness, quality, and 
availability of the animal models; for the humane- 
ness and appropriateness of procedures and con- 
ditions surrounding animal subjects before and 
throughout the study; and 
• to evaluate, at least annually, the animal research 
facility and recommend appropriate actions to cor- 
rect deficiencies noted (11). 
Proposals are reviewed again at a regional VA office 
by two committees, first for veterinary medical review 
(appropriate use and care of animals) and then for scien- 
tific merit (10). The animal welfare review is done by 
a Veterinary Medical Panel of specialists chosen for 
their experience, knowledge, and research in labora- 
tory-animal science and medicine. This panel attempts 
"to assure that proposals include sound, acceptable ani- 
mal medicine and husbandry practices in animal re- 
search facilities that are operated in conformance with 
all pertinent animal welfare laws, regulations, and pol- 
icies” (11). Specifically, the panel conducts reviews: 
• to ascertain the description of the animal model; 
• to ascertain the biological and medical definition 
of the animal model; 
• to ascertain the environmental and experimental- 
animal-related factors; 
s • to determine if there is evidence of adequate ex- 
perience with the proposed technology of manipu- 
lations, monitoring, or measuring; 
• to determine if use of intact animals is required 
or if animal parts could be obtained from or shared 
with other investigators who have scientifically 
compatible studies; 
• to determine if painful procedures are involved 
and whether these can be avoided or if their con- 
trol has been satisfactorily planned; and 
• to relate the budget of the experiment to the ani- 
mal costs and to the animal maintenance needs (11). 
In 1984, the VA required that all research proposals 
have an appendix with a detailed discussion of animal 
protocols, the number of animals to be used, and why 
the specific choice of organism was made. This appen- 
dix is signed by three people from the local facility— 
the researcher, the animal committee chairperson, and 
the research and development chairperson— to guar- 
antee that the procedures are carried out. 
The enforcement of the VA's animal research pol- 
icies rests with the committee structure and is over- 
seen by the Chief Veterinary Medical Officer for the 
VA, whose duties include making sure all Federal and 
State animal research laws are observed and that the 
individual facilities have the funds to continue to re- 
main AAALAC -accredited. In addition, the VA began 
in fiscal year 1984 strict enforcement of the comple- 
tion of the Annual Reports of Animal Research Facil- 
ities for APHIS by every VA facility, whether the facil- 
ity used animals in research the preceding year or not 
( 10 ). 
At the local VA facilities, the attending veterinarian 
has authority for veterinary medical matters. This per- 
son must monitor the housing, general treatment, and 
care of the experimental animals while the experiment 
is in progress as often as needed. If inhumane treat- 
ment or inappropriate care is found, the veterinarian 
and animal subcommittee do not have the authority 
to interrupt or terminate an experiment. The subcom- 
mittee would make a recommendation to the research 
and development committee and to the Associate Chief 
of Staff for Research and Development, who may make 
a decision or a recommendation to the Director (4). This 
means there is some enforcement of the proper ani- 
mal care standards at each local VA facility on a day-to- 
day basis. 
Appendix B References 
1. Borsetti, A., Staff Scientist, Office of Science Coordina- 
tion, Food and Drug Administration, U.S. Department of 
Health and Human Services, Rockville, MD, personal com- 
munications, October and November 1984 and March 
1985. 
2. Chernoff, N., U.S. Environmental Protection Agency, Re- 
search Triangle Park, NC, personal communication, 1984. 
