tain. In my opinion the standards necessary in medical research should be the responsibility of the Department of Health, Education, and Welfare: the U.S. Public Health; or the National Institutes of Health: and not the Department of Agriculture.

Furthermore, as proposed in section 16, to allow an inspector to use his own judgment as to when an experiment is ended and to permit the inspectors to confiscate or destroy an animal without giving the research worker an opportunity to present to an impartial board the nature of the experiment and his reason for considering the experiment not terminated is completely unjustified.

Scientists today are tremendously interested in late and long-term effects and to permit a person to interrupt their work without due course to law, I believe, is fundamentally wrong. Inspection should be made by persons qualified both in regard to the care of animals and the nature of the research, and the problems involved therein, and their findings should be reported to a board to whom the offender can appeal. In the eyes of the law of our country all persons are innocent until proved guilty.

A further objection to the bill is that to properly administrate the bill and to equitably enforce the law throughout the 2,000 medical and research institutes, not to mention the zoos, roadside zoos, circuses, and pet shops, even omitting the kennels, the veterinary hospitals, veterinary centers, animal shelters and the pounds, and the humane societies, would require a tremendous team of knowledgeable men, a far larger number than are now available.

To inspect any of the large medical institutions in this country would require 2 to 4 days time and certainly all such inspection should be made independently by at least two different inspectors with two different interests, in order to insure against the bias of any one inspector. The latter precaution is mandatory, if failure to comply with any single point in the law, in any department of a large institution. penalizes the entire institution.

In view of the great size of many research institutions and universities, section 20, Public Law 89-544 should be revised and amended so that only that department or division of the university which is at fault is penalized. Human we all are and with the best will in the world, some errors are inevitable, not only in the handling and treatment of animals, but also in the judgment of the inspectors. Medical science in any large institution should not grind to a standstill because of a single error on either side.

To have this law equitably administered would require millions of man-hours and billions of dollars-I think far more than Dr. Herner estimated, millions of dollars. Far more would be accomplished toward the objective of this bill and the taxpayers' money would far better be utilized for the benefit of society if a fraction of these funds were made available for the improvement, updating, and maintaining of adequate animal facilities, and for the training of personnel in the care of laboratory animals.

All of the organizations which I represent are deeply interested in the welfare of man. Nevertheless, for the above reasons they are strongly opposed to the Whitehurst bill-H.R. 13957.

Finally, may I ask to have the testimony which I have brought over in part, the American Association for Laboratory Animal Science,

and the American Association for the Accreditation of Laboratory Animal Care, appended to my record.

Thank you. That completes my testimony.

Mr. PURCELL. Doctor, whose testimony is it you are asking to be inserted in the record?

Dr. TAUSSIG. From the American Association of Laboratory Animal Science and the American Association for the Accreditation of Laboratory Animal Care. They wrote out their own testimony.

I am representing the ones on this list. And they sent in separate testimony. This was the broad testimony for all of them that I have presented today.

Mr. PURCELL. I am sure that if we knew these people that are members of the board of trustees we would all be impressed, but I am not sure that it would accomplish anything by burdening the record with all these names of schools.

Dr. TAUSSIG. That is a matter of your judgment, Mr. Chairman. Mr. PURCELL. We will take out the statements themselves, and we will allow those to be inserted, but not just put in a list of names and schools.

Dr. TAUSSIG. They were sent over and we thought you might be interested in what the association had done in this respect.

Mr. PURCELL. We are very interested, but we see a lot of pedigreed people up here, so maybe we do not get carried away as we should. So we will be glad to have the statements themselves.

(A list of laboratory animal facilities fully accredited by the American Association for Accreditation of Laboratory Animal Care, and a list of the members of the board of trustees of that organization may be found in the files of the committee. The two statements referred to by Dr. Taussig appear after her testimony.)

Mr. PURCELL. Are there questions of this witness?

Mr. Jones?

Mr. JONES. Can you elaborate on the last sentence of your statement, please, Doctor, "Far more would be accomplished toward the objective of this bill and the taxpayers' money would far better be utilized for the benefit of society if a fraction of these funds were made available for the improvement, updating, and maintaining of adequate animal facilities, and for the training of personnel in the care of laboratory animals.”

Dr. TAUSSIG. I think there has been great improvement in the handling of laboratory animals through research facilities. But throughout the country, with the rising cost of medical care, there has been a tendency to cut corners. And many times corners have been cut, and the amount of money allocable to animal care has been cut. They need funds. They wish to improve the care, in many of the laboratories they are anxious to do it, and they are trying to find funds to do so. And it is only recently that they have sent in the experienced men and the technicians in the handling of laboratory animals. And it is almost a new branch of technology that is coming out in our country.

There are only a comparatively few men trained in that field in comparison to the need. And rather than hiring the most menial person to do the job, the need is to have somebody who knows how to handle the animal properly, and who can recognize sicknesses and see

that cages are cleaned, somebody who is there all the time and not someone who goes home at 5. It takes a great deal of intelligent help.

I think it is customary for a lot of people to work from 9 to 5, but you should have a person in over the weekend who knows how to handle the animal and see that things are done properly.

And there is a great need for training people in that regard. Thẹ NIH is beginning to give grants, but we have not begun to fill the need for all the medical research in this country in research institutes. Does that answer your question, Mr. Jones?

Mr. JONES. Yes; thank you, Doctor.

Mr. PURCELL. I have one question, Doctor. I have been impressed with the fact that none of the witnesses so far have had any real estimate of the cost of this other than the Department witness this morning. But now would you briefly tell me what you are going by when you make a statement on the next to the last page of your written testimony that it would probably cost billions of dollars. What are you basing that on?

Dr. TAUSSIG. I am basing it on what it would cost for the accreditation people, say what it costs for the number of institutes that come in, the number of places, and what it would cost for a careful inspection within the large institutes, really inspecting every division that is handling animals. Let us say it would take 2 to 4 days to do Hopkins and other large institutes over the country. It will take manpowerdays. And you will have to pay the men, and you will have to pay the time and travel.

I think it would be a colossally expensive undertaking.

Mr. PURCELL. Of course, the factors that you stated are very elementary in having any kind of inspection. And when you say it would be colossal, you are using the word "billion" fitting with "colossal," I take it? You do not have any estimate or study or any actual figures that you or anyone else has developed in this regard, is that correct?

Dr. TAUSSIG. No. I think that the accreditation of animal care would tell you how much it cost per university that they have. I do not have the figures at hand. But it is a very sizable amount. I would be glad to give you the figures on that.

I do not believe it is in the testimony.

Mr. PURCELL. Do you have any method of getting figures based on reality or a realistic study?

Dr. TAUSSIG. I could try to get you some.

Mr. PURCELL. I thought maybe with accessibility to all these institutions and people that you might have someone who is an expert in this field that would have a good estimate on it. If you do not have, we will get the figures from someone else. I just wondered if you had a source of that kind.

Dr. TAUSSIG. Dr. Melby would be the person who has it if anyone does. I would be glad to let you know later in the day.

Mr. PURCELL. Who are you speaking of?

Dr. TAUSSIG. Dr. Edward Melby, who is head of our animal care. Mr. PURCELL. If he has any figures, and you can get them today conveniently, we will appreciate having them.

Thank you.

(The information requested of Dr. Taussig by Mr. Purcell for inclusion in the record at this point and the two statements previously mentioned, follow:)

ADDITIONAL INFORMATION SUPPLIED BY DR. HELEN B. TAUSSIG

National Institutes of Health: Estimates for upgrading animal facilities in N.I.H. eligible Institutions.

(Does not include drug firms, zoos, S.P.C.A.'s, shelters, pet shops, etc. Not including state universities and School of Agriculture)

Total cost for implementation, $350,000,000 to $400,000,000

Johns Hopkins Medical Institutions: 1⁄2 million for automation and improvement-on campus; 3 million for off campus support (Farm animals, breeding, and professional staffing.)

Cost of single accreditation inspection by A.A.A.L.A.C.-$500.00 to $1,000.00 depending on the size of the institution requesting inspection.

14. 0

42.0

2.5

388.5

STATEMENT OF THE AMERICAN ASSOCIATION FOR LABORATORY ANIMAL SCIENCE, JOLIET, ILL.

The American Association for Laboratory Animal Science is an organization comprised of persons with professional interest in laboratory animal science. Membership of the American Association consists of 2,300 physicians, veterinarians, dentists, research scientists and animal technicians at approximately 300 institutions which use laboratory animals in research and education. The American Association is a non-political organization and as general policy does not involve itself in matters of Federal and State legislation. However, the Bill before this Committee, HR 13957, would have its greatest impact on the members of the American Association and the research and educational projects which they are conducting. The American Association is the only national organization of individuals directly involved in the use of laboratory animals for research and education. The American Association was founded in 1950 on the general principle that increased education of scientists and technicians in the use of laboratory animals will improve standards of laboratory animal care and the value of the results of research and educational programs using animals. Good animal care is an essential prerequisite to getting valid research results. Proper care for laboratory animals is not a matter of intuition. An untrained person or selftrained person is not in a position to evaluate standards of care and the relevancy of various aspects of animal handling to research and educational projects. This takes the expertise of someone who has undergone extended training.

The untrained person can only impose his own instincts and subjective determination as to what constitutes proper use of laboratory animals. The untrained person uses his visceral reaction to determine what is good and what is bad laboratory animal care, resulting in some instances in unnecessary interference with research and animal well being, and other times in missing negative situations which need correcting. This visceral reaction is all that is needed and the American Association for Laboratory Animal Science has wasted its time and the time of its members for the past twenty years. Because this organization's function is to provide continuing education programs in laboratory animal science for persons who usually have an extended form of postgraduate education before they even start to work in animal laboratories. Naturally we do not believe that this time has been wasted and this organization believes in education and continuing education of full time experts in the field of laboratory animal science as the way to improve laboratory animal care and the resulting scientific information. Professional members of the American Association usually have one or two or more professional degrees added to their Baccalaureate. They receive subscriptions to Laboratory Animal Care, the official journal of the American Association. They attend seminars, lectures and other scientific programs conducted by the

American Association and its regional branches. We estimate that 250 to 300 scientific lectures and seminars were conducted last year, attracting more than 2,000 persons in attendance, some of course attending more than one session.

The technicians who are members of the American Association also receive the scientific publications and the Journal Laboratory Animal Care. In addition, the American Association conducts a certification program for technicians which encourages and rewards continuing education. The American Association believes that it would be a substantial error to subject the trained laboratory scientists to the visceral reactions of the self-acclaimed experts in laboratory animal care. No substantial increase in laboratory animal care could be expected. Instead, we would find it interference with the progress that is being made both in animal care and in medical science. For this reason the American Association recommends to the Committee and to the Congress that no legislation should be adopted which would subject laboratory animal science to the interference of well meaning persons who would seek to substitute their visceral reaction for education and training. The American Association for Laboratory Animal Science has not ignored the fact that laboratory animal care can benefit from objective criticism, from well trained and educated persons who are experts in this field, and at the same time dedicated to the improvements of laboratory animal care. For this reason the American Association supports the creation of the American Association for Accreditation of Laboratory Animal Care a peer review organization conducting a voluntary program for upgrading laboratory animal care.

Some time ago an editorial appeared in one of the Washington newspapers referring to a peer review program as the fox guarding the chicken coop. The point in the editorial was that the research scientists themselves are the foxes and the persons least qualified to judge laboratory animal care. This is nonsense. It is only the research scientist who can judge laboratory animal care. They are the only ones who use educational training and experience in laboratory science instead of the visceral reaction.

Perhaps the fox and the chicken coop example assumes that the research scientist favors poor care and is a fiend dedicated to causing pain and suffering to research animals. This is so illogical that no rebuttal is required. The problems that exist arise out of insufficient funding and need for additional training, old facilities and general problems relating to a relatively low priority position with respect to getting sufficient funding. An inspection program conducted by anyone other than those persons qualified in laboratory animal science would only add to the problems and achieve nothing. The voluntary accreditation program provides peer review and consultation, which demonstrates to the offending institutions that their peers have examined them and found them wanting. As will be discussed by the American Association for Accreditation of Laboratory Animal Care this has been a productive means for getting the necessary funds that has resulted in the improvement of laboratory animal care.

In summary, the American Association opposes any program for inspecting and evaluating laboratories using animals, which is conducted by persons who are not themselves educated and experienced within the field of laboratory animal science. Science and education should not and cannot be subjected to interference from well meaning but unqualified persons who believe their intuition is a better standard than years of university education. The American Association favors the voluntary concept of the American Association for Accreditation of Laboratory Animal Care as a proper agency for conducting a continuing program for upgrading the standards of laboratory animal care. The Bill provides for the Secretary of Agriculture to set standards for laboratory animal care. The American Association questions the advisability of this action as standards already exist created by the Institutes of Laboratory Animal Resources of the National Research Council, in consultation with the National Institutes of Health, Department of Health, Education and Welfare and contained in the "Guide for Laboratory Animal Facilities and Care". This "Guide" is used as a standard for accreditation with the American Association for Accreditation of Laboratory Animal Care. The second set of standards promulgated by an agency heretofore not involved in laboratory animal science seems to be ill-advised. The American Association offers its services to the Committee and will be pleased to provide whatever additional information which it possesses which the Committee believes can be used in arriving at an appropriate decision relative to the legislative proposal which is presently before the Committee.