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If you are not directly involved with animal research protocol writing, you may not know what IACUC stands for. In 1985, Congress passed the Improved Standards for Laboratory Animal Welfare Act, which took effect on January 1, 1987, requiring research facilities to establish Institutional Animal Care and Use Committees (IACUC) to monitor animal care and inspect facilities. There are undeniable problems with this legislation both on philosophical and practical grounds.

Philosophically speaking, United States Department of Agriculture (USDA), the enforcing agency of Animal Welfare Regulations, bases its legislative assumption on common sense. For example, if a procedure is expected to cause pain or distress in a human subject, a pain-relieving drug must be used on animals subjected to the same or similar procedures¹. What’s the problem? USDA stipulations clearly imply that we, as a community, agreed to use animals as surrogates for human subjects in research where pain, distress, illness, or other harm may occur. Surrogacy increases the moral status of the research animal on the level where moral and ethical issues can no longer be avoided. By education, “scientists are guided with a mainstay view that science ought to make no assumptions, postulate no entities, and countenance no terms which cannot be cashed empirically.”¹ In this view, USDA enforcements reflect a metaphysical stance, not an empirical one, thus posing a clear contradiction to orthodox science education.

Legislation becomes even more problematic when put into practice. The USDA’s top-down enforcements put the IACUC members in a very difficult position. Many scientists see IACUC as an illegitimate intrusion by non-experts into their freedom of inquiry, rather than a legitimate moral stance¹. This is particularly problematic as, by law, IACUC protocol review must include non scientists and/or non-affiliated members.

It is unreasonable to expect a healthy and stable research environment when disagreements are deep and persistent among the policy-makers, IACUC, and researchers. Animal regulations/ethics cannot be coerced by policy, not until a definitive ethical consensus is established.

In response to an article in ILAR News (Prentice et al. 34 (1-2): 15, 1992), Dr. Jonathan Black from Clemson University argued that in research involving animals the ethical “buck” begins and stops with the principal investigator, regardless of the advice of IACUC. In response to that, Dr. Ernest D. Prentice reminded Dr. Black that Congress has the power to make whatever laws are consistent with the constitution, and it is Congress that has decided that animal research must be regulated and monitored by the Public Health Service (PHS) and the USDA. It is these organizations that have decided that IACUC must serve that role at the institutional level². The argument is not unfamiliar to those who serve on Animal Care Committees and to those scientists who must do their research through animal work.

At the core, this and similar arguments represent problems stemming from the lack of coherent consensus ethics on animals and a lack of appropriate education accordingly. As a result, IACUCs are a bit like jurors being asked to adjudicate without being given the law¹ and the researchers are like drivers being asked to drive without traffic signals. It is unreasonable to expect researchers to grant animal regulations/ethics when scientific doctrine continuously instructs them to do pure science.

For prospective animal researchers, bioethics and animal welfare courses must be included in science education curriculums; they will provide the vision that steers future scientists toward appropriate action and will enable researchers to act as catalysts on both animal welfare and ethics. Top-down enforcements are a failing approach and IACUC’s regulatory obligation mostly falls on formalities merely to assuage legislators.

Those who believe that inclusion of ethical and animal welfare issues in mainstream science education will impair scientific enterprise must be reminded that this addition is about more than whether ethics has a place in science. The public, which overwhelmingly supports valuable animal research that is humanely conducted, demands accountability. Since the NIH (National Institute of Health), a major funding agency in the US, demands this accountability through ethical cost benefit, the question becomes more obvious. Is it far better for science to police itself than have some external agency or internal committee perform this function? If the answer is yes, then we may all have new responsibilities to assume.

IACUC may begin with shifting from an internal police to institutional facilitators of continuing education toward the combination of study and action that will foster the scientific vision of the researchers and by joining them in constructing a healthier and more stable research environment.

References:

¹ Rollin, Bernard (1998), The Unheeded Cry. Iowa State University Press.

² Letters to the Editor, ILAR News, Volume 35, Number 1, Winter 1993.