In 2014, as part of NAVS’ efforts to advocate for increased transparency regarding animal use in the U.S., we filed a formal petition for rulemaking with the United States Department of Agriculture’s (USDA) Animal and Plant Health Inspection Service (APHIS) asking APHIS to expand its collection and reporting of animals used in research.
It took APHIS more than four years to respond to our petition. And their reply was extremely disappointing.
In our petition, NAVS noted that APHIS’ current data collection and reporting methods could be improved by including more information, such as basic details regarding the specific purposes for which research animals are used in the U.S. This information is key to understanding trends in animal use in different areas of research and helps reveal those areas that should be prioritized for the development of alternatives.
The absence of this data also leads to confusion and misinformation about how animals are being used, as animals used in benign procedures—such as nail clipping, teeth and ear cleaning, and spaying and neutering of shelter dogs in preparation for adoption—are lumped in with harmful experiments such as toxicology testing.
The USDA published our petition for public comment in the Federal Register in June of 2015 and it received an overwhelmingly positive response. The USDA received 1,724 comments: 1,473 (85%) were in favor, 201 (12%) did not address the petition but expressed general opposition to animal research. In the end, only 50 comments (3%) opposed our petition.
In her response to NAVS, Bernadette Juarez, Deputy Administrator of Animal Care at APHIS acknowledged the overwhelming support of the petition, noting, “Those in favor expressed the need for transparency and more detail on the animal use so as to promote accountability. Several expressed the public had a right to know because taxpayer money is being used to fund research. Others made the point that greater detail can result in identifying alternatives to animal use.”
Despite this, APHIS indicated that it would not be making any changes to the way it collects and reports on animal use. The agency justified their decision to maintain its current data collection and reporting practices by claiming that it lacked the authority to make the changes that we requested. However, the fact of the matter is, the changes we proposed to increase transparency regarding research animals were, in fact, within APHIS’ purview, and were ones that could have been adopted by the agency, just as it made available new online reporting for licensees. Instead, APHIS just chose to deny our request.
Though this particular path toward animal use transparency has been blocked by our government, NAVS is going to continue to fight for increased access to information—and we want you to do the same.
While we prepare our response to APHIS, we encourage you to continue to demand transparency by supporting the FACT Act, which would require federal agencies to describe the progress they are making in developing, validating and utilizing alternative methods instead of using traditional animal tests. It would also require agencies to report on their animal use data by species, number and test type for toxicological testing being conducted.