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Our associations have a sincere interest in the care of laboratory animals. is our position that the problems related to laboratory animal care are interined with programs of research and education and that they should accordgly be considered separately from the problems of cat or dog theft and the re of animals prior to their arrival at a research facility.

UPPLEMENTARY STATEMENT OF THE AMERICAN DENTAL ASSOCIATION AND THE
AMERICAN ASSOCIATION OF DENTAL SCHOOLS

As indicated in a statement submitted to the Senate Committee on Commerce n March 30, 1966, the American Dental Association and the American Associaon of Dental Schools are in "sympathy with the intent of those who . . . wish O prevent the theft of household pets and to provide for adequate standards f care for such animals while being handled by dealers."

These objectives would be achieved by enactment of either H.R. 13881 which Las passed the House of Representatives or S. 2322 as orignially introduced. 30th of these bills strike a generally reasonable balance between the desirable goals of preventing the theft of dogs and cats and the necessity of preserving he freedom essential to research scientists if they are to progress in their fight against human pain and disease. It is believed, however, that the amended version of S. 2322 is not so well designed and would, in fact, severely and unnecessarily handicap much of the vital health research now being conducted in che scientific community.

A major defect of S. 2322 as amended is that its provisions for licensure, inspection, record-keeping, etc., would impose an enormous burden on research institutions that would hamper and perhaps bring to a standstill much of the important health research now being conducted. The vaguness of the bill's provisions regarding confiscation and destruction of animals, and inspection of records by local law enforcement authorities might well lead to unnecessary interference with and disruption of legitimate research activity and provide an invitation to harassment by those who are opposed to all experimentation and research involving the use of animals.

A second important defect in S. 2322 as amended is that it does not recognize the real problem of improving conditions in the whole research community so that animal care standards can be met within a reasonable period of time. Nor does it take into account the steps already taken by the scientific community itself to provide standards for the humane care of laboratory animals. American Association for the Accreditation of Laboratory Animal Care, a private agency of which the Association is a founding member, is already in operaThe tion and, indeed, has begun accrediting facilities.

A third major defect of S. 2322 as amended is that it places regulatory authority over biomedical research and educational institutions under the jurisdiction of the Department of Agriculture which has no expertise in the field and no established relationship with such institutions. It would be far more reasonable to place such responsibility within the Department of Health, Education and Welfare which not only has the personnel and experience but already administers the basic Federal programs in the area of health research facilities, training of professional laboratory animal personnel, laboratory animal care research and overall improvement of laboratory animal resources. Jurisdiction

in this area clearly lies within the Department of Health, Education and
Welfare.

There is presently pending before Congress a measure, S. 3332, that does take
account of private steps being taken, does acknowledge that Federal responsi-
bility properly belongs to the L'epartment of Health, Education and Welfare
and does provide Federal assistance for upgrading standards wherever this is
judged necessary.
animal care standards by requiring as a prerequisite to receiving a Federal
This bill, in addition, will assure adherence to adequate
research grant, that an applying institution "be accredited by a recognized body
or bodies approved for that purpose by the Secretary of Health, Education and
Welfare." The Associations believe that S. 3332 is well-designed to meet the
precise requirements of laboratory animal care standards that are high in
quality and nationally uniform. S. 2322 as amended, on the other hand, would
unduly hamper the research effort of the nation, unnecessarily duplicate efforts
already underway in the scientific community and place Federal responsibility in
an inappropriate agency. Consequently, we urge the Committee to disapprove
S. 2322 as amended.

STATEMENT OF THE AMERICAN FEED MANUFACTURERS ASSOCIATION

The American Feed Manufacturers Association appreciates this opportun to present its views to the Senate Committee on Commerce concerning S. 22 S. 3059, and S. 3138. We condemn the theft of pets for any purpose and the treatment of these animals which has sometimes followed. We feel, howeTe that it would be unfortunate if legislation intended to correct this obvious e were to be permitted to interfere with the nutritional research which is esse ial to our Nation's food supply.

We would like to call to the attention of the committee the large amour: nutritional research which is conducted in the United States each year inv ing hundreds of thousands of head of farm animals-livestock and potr This research is carried out by agricultural universities in every State, by 2 U.S. Department of Agriculture, by feed manufacturers and by other prin companies. We are hopeful that the problems of pet stealing and mistreatme can be corrected without developing legislation which will hamper farm ani nutritional research and thus increase the cost of meat, milk, and eggs over t prices which would otherwise prevail.

Livestock and poultry theft is not a substantial problem in the United State One of the reasons for this is that in many communities the penalties applied those caught stealing livestock or poultry have been far more severe than th penalties proposed in these bills. Also, animals for feeding trials can be reall purchased from farmers and/or hatcheries (in the case of poultry). Thus sp cial legislation concerning the stealing of farm animals is not needed.

Nutritional research with farm animals is quite different from most medic research as described by witnesses during the March 25 and 28 hearings. Nu tional research normally involves feeding comparisons-such as feeding the lay ers in one chickenhouse as a ration containing vitamin A as obtained from one gredient while the layers in an identical house are fed a ration containing vit min A as obtained from another source. Many of the animals which are pr chased for nutritional research are purchased from individual farmers. Moct of the poultry which is purchased for nutritional research is purchased fro hatcheries which are primarily in the business of hatching chicks, poults, etc. for sale to farmers. Farmers and hatcheries should not be burdened with s licensing procedure, recordkeeping, etc., as a side effect of the problems of pel stealing and subsequent mistreatment of the pets. Also, this would increas costs and would result in higher cost meat, milk, and eggs in the future.

Nutritional research has contributed much to the high standard of living whit U.S. citizens generally enjoy. It has been an important factor in making it pe sible for the U.S. population as a whole to obtain a plentiful supply of tasty, api petizing, nutritious, and wholesome foods at a cost of less than 20 percent of our disposable income, while the citizens of most countries have to spend the major ty of their income for food. Nutritional research is a major factor contributi to the increasing quantities of meat, milk, and eggs which most U.S. citizens cal purchase with an hour's wages. The quantities of these products which ca be purchased with an hour's wages are substantially higher than was the cast 10, 20, or 30 years ago.

Specific evidence of the great strides which have been made in the handlic and nutrition of farm animals is provided by information recently published by the U.S. Department of Agriculture. In 1965, only 2.55 pounds of feed wer required (U.S. average) to produce a pound of broiler as compared with 3.9 pounds of feed in 1948. This represents a 35-percent improvement in feed efficiency which could not have occurred if the animals were being mistreated U.S. farm animals probably are the best fed and best cared for of any animals i the world.

We respectfully request that livestock and poultry be excluded from an legislation which the committee approves following the March 25 and 28 hear

1 "Poultry and Egg Situation," U.S. Department of Agriculture, November 1965.

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igs. S. 2322 and S. 3138 do not include nutritional research with farm anials, but S. 3059 probably would be interpreted to include this type of research. Thank you for the opportunity to present this statement.

OAKLEY M. RAY, Vice President.

STATEMENT OF THE AMERICAN MEDICAL ASSOCIATION

The American Medical Association supports programs which protect pets from heft and insures the humane care of laboratory animals. We deplore any im›roper trafficking in experimental animals. We deplore any substandard care.

We are aware of increasing publicity concerning this subject matter. Det stealing and improper care of dogs and cats by animal dealers may not be videspread, we firmly agree that any improper practices which do exist in the While procurement of experimental animals should be corrected.

Because of our interest in this subject matter, we are pleased to have the opportunity to present the association's views on S. 2322 and S. 3059. At the outset we note that, while S. 2322 is restricted to cats and dogs, S. 3059 is applicable to eats, dogs, and other vertebrate animals.

These bills would authorize the Secretary of Agriculture to regulate the transportation, sale, and handling of dogs and cats and other animals intended to be used for purposes of research or experimentation. The regulation of these activities is stated in the bills to be necessary in order to protect the owners of dogs and cats and other animals from theft of such pets, and to prevent their sale or use for purposes of research and experimentation. We do not believe, however, that this legislation should go beyond the elements necessary for the accomplishment of this goal. Accordingly, we urge that the following two aspects of the bills be modified:

(1) Licensing of research facilities.-S. 2322 and S. 3059 would require research facilities to obtain a license from the Secretary of Agriculture upon demonstration of compliance with standards promulgated by the Secretary. We view this provision as unnecessary and unwise.

The particular intent of the bills is to prevent the reprehensible theft and inhumane acts in procurement of animals for research purposes. To achieve this goal, it is proposed that dealers involved in the procurement and transportation of animals be licensed in accordance with specified standards. We have indicated our support for the intendment of this provision. By extending licensing requirements to the research facility, however, there is, at least by implication, the suggestion that such facilities are linked to pet stealing or inhumane treatment.

Such is not the case.

It is grossly unfair to "tar with the same brush" these research laboratory facilities and the nefarious animal dealer whom we all wish to eliminate. The standards of animal care in research facilities in the United States are generally high. The voluntary activities of groups or associations which are concerned with animal research, such as the National Society for Medical Research, the Animal Care Panel, the Institute for Laboratory Animal Research, and the American Association for the Accreditation of Laboratory Animal Care, are effectively accomplishing the goal of maintaining good animal care in the laboratory.

The biomedical research community has achieved high standards with respect to treatment of laboratory animals, by processes of self-examination and voluntary regulation. As examples of just two laboratory animal facilities, we are submitting photographs taken at our own Institute for Biomedical Research

and at G. D. Searle & Co., a pharmaceutical manufacturer in StA through G):

[graphic]

Examination of dog by veterinarian. Research laboratory GI Skokie, Ill. (March 1966).

[graphic][subsumed]

Research laboratory, G. D. Searle & Co., Skokie, Ill. (March 1966).

Technician examining white rat.

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