National Anti-Vivisection Society petition aims to improve quality and quantity of available information regarding animal experiments
UPDATE (8/25/15): The public comment period for NAVS’ petition for rulemaking is now closed. More than 1,700 comments were received—an overwhelming majority in support of the petition. Included among the responses were additional comments submitted by NAVS in response to objections raised by individuals and organizations that use or support the use of animals for research.
The National Anti-Vivisection Society (NAVS) announced today that the United States Department of Agriculture’s (USDA) Animal and Plant Health Inspection Service (APHIS) is soliciting public comments on a formal Petition for Rulemaking filed by NAVS. The Petition asks that APHIS amend its requirements for recordkeeping and reporting on the use of animals by entities, including research facilities, which are licensed by the USDA under the Animal Welfare Act.
In its Petition, NAVS notes that APHIS’ current data collection and reporting methods lack the scope and detail found in the system used in the European Union. The EU system, the Petition states, “provides an accurate and transparent accounting of how many, what type of animals, and for what specific research, testing and educational purposes the animals are being used.” The current APHIS system, in contrast, provides no information pertaining to the specific purposes for which the animals are used in the United States.
Such a deficiency, NAVS observes, hinders progress toward the implementation of what are commonly referred to as the “3Rs”—reduction, refinement and replacement—of animal use.
“More accurate information regarding the specific ways in which animals are currently being used is the key to effective implementation of the ‘3Rs,’” says NAVS’ Executive Director Peggy Cunniff. “The additional data that NAVS is asking APHIS to request of USDA licensees will be essential not only in measuring progress toward reducing and replacing the use of animals, but also in identifying priorities for future funding.”
APHIS is now soliciting comments from the public to ascertain whether they should move forward with amending their regulations and specifically what information, if any, is lacking in current reporting requirements. After reviewing comments, the agency could choose to move forward with changes to its data collection on animal use by research laboratories and other licensed institutions.
NAVS’ Petition notes that APHIS’ current system can lead to “confusion and misinformation” about animal use, as without accurate data regarding how animals are being used, 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.
“What we’re advocating for with this Petition is simplified access to meaningful data,” notes NAVS’ Director of Legal and Legislative Programs Marcia Kramer. “Researchers are already collecting this basic information. All we’re asking is that it be included in licensee reports, and, to assist with this, we are proposing a simplified method of reporting all required information.”
Federal guidelines require APHIS to release information pertaining to the number of animals being used for research, testing and teaching by USDA licensees. In 2014, primarily as a result of NAVS’ efforts, APHIS resumed publication of its online Annual Report detailing this information.
The Petition for Rulemaking, ID No. APHIS-2015-0033-0001, will be open for public comments on the Federal eRulemaking Portal through August 24, 2015.
How You Can Help
APHIS is encouraging all members of the public to comment on NAVS’ proposal for expanded collection and reporting on data pertaining to the use of animals used in research. Below are some key points you may wish to consider when crafting your personal response:
- Current U.S. requirements for recordkeeping and reporting on the use of animals in research, testing and teaching are inferior to those used elsewhere in the world.
- APHIS records provide less accountability and transparency for the public, as they lack basic information on how animals are being used in this country.
- Most research is carried out with public funds. The public has a right to know how tax-payer funds are being used.
- More meaningful information on animal use is essential to improving animal welfare and promoting advancements in science.
- Federal regulations require consideration of alternatives to the use of animals in research, testing and education. Reliable statistics on animal use are central to understanding how well the 3R’s—reduction, refinement and replacement—of animal use are being implemented.
- Collection of more meaningful information on animal use will be invaluable in helping federal government agencies, licensees and the public in developing strategies to ensure that federal regulations are followed.
- A revised system of recordkeeping would not place an undue burden on research facilities or APHIS, as the new system would streamline reporting into a more comprehensive and functional electronic format.
- The new data collection that that has been proposed is information that research facilities already compile in-house.
- Annual Reports should contain the following information:
- the number of each species of animals used in research;
- the source from which these animals were acquired;
- the genetic status of the animal;
- the purpose for which they are being used (including but not limited to biological studies of a fundamental nature, research and development of products and devices for human medicine and dentistry and for veterinary medicine, toxicological and other safety evaluations, education and training, etc.);
- the number of animals used in toxicological and other safety evaluations;
- the proportion of animals used for studies of diseases;
- the category of pain/stress under which they fall; and
- registered research institution contact information.
- The timely reporting of more comprehensive data in an Annual Report should result in significantly fewer requests under the Freedom of Information Act (FOIA), thereby reducing the amount of resources expended by research institutions and APHIS staff to fulfill FOIA requests.