Executives at a Harvard University-based legal clinic question whether a federal agency is risking the welfare of research animals by performing partial and targeted inspections, rather than full inspections, of certain research facilities.
In response, officials from the Animal and Plant Health Inspection Service of the Ministry of Agriculture say that far from weakening the inspection process, the risk-based inspection system makes the best use of the resources of the organization. agency by focusing attention on the facilities that need it most.
In early May, Science magazine published an article outlining an APHIS policy allowing targeted inspections under the Animal Welfare Act of research facilities accredited by AAALAC International, a private, non-profit organization that includes ‘AVMA among its member organizations.
Full or targeted inspections
APHIS and Harvard University Animal Law & Policy Clinic officials disagree on whether full inspections are required under the AWA and whether targeted inspections can provide sufficient guarantees that research animals are treated well.
Katherine Meyer, director of the Harvard Legal Clinic, said in a message to JAVMA that the law requires full inspections every year to ensure that laboratories meet minimum standards of humane treatment.
Animals are already sacrificing their lives, she said, and they deserve protections that ensure their care.
The Harvard Clinic provided a copy of a USDA memorandum, labeled “for internal use only,” which states that APHIS adopted a policy in February 2019 that required only targeted inspections to be performed at medical facilities. AAALAC accredited research, unless facilities require full inspections. The document indicates that, of the first 322 inspections carried out since the policy was adopted, 151 were at AAALAC-accredited facilities, and 91 of those facilities underwent targeted inspections.
“We heard that some facilities requested a full inspection because they feared the emergence of a ‘targeted inspection’ (since such inspections have always taken place in response to complaints about animal welfare or animal welfare. direct non-compliance), ”the USDA note states. “We’ve also heard that facilities and inspectors value the ability to focus inspection, and inspectors remain confident about the welfare of animals at the facility.”
APHIS spokesperson Lyndsay Cole said AAALAC accreditation is a factor considered in determining whether a facility will undergo a targeted inspection, as is a facility’s previous compliance with the AWA. Inspections go unannounced, laboratory facility managers do not know whether they will be subject to a targeted inspection, inspectors can decide at any time to conduct a full inspection instead, and the agency keeps records. information on how it determines which facilities will receive targeted inspections versus full inspections. confidential.
Inspection standards and practices
Dr Kathryn Bayne, CEO of AAALAC International, said in a statement that the organization strives to ensure responsible care and use of animals and that AAALAC’s accreditation program is complementary to inspections of the ‘USDA. A USDA policy of performing targeted inspections by default at all AAALAC accredited facilities would be impractical as USDA and AAALAC International have substantial differences in their surveillance programs, she said. declared.
Dr Bayne noted that AAALAC’s accreditation standards exceed federal requirements and that its accreditation program is part of an animal research oversight matrix that includes APHIS and the National Institutes of Health Office. of Laboratory Animal Welfare. AAALAC has been promoting the humane and responsible care and use of research animals for over 50 years, she said.
Dr Stuart Leland, chairman of the Veterinary Consortium for Research Animal Care and Welfare and director of research integrity and assurance at Princeton University, believes federal law gives APHIS the discretion to conduct its investigations and decide on the best way to ensure the welfare of the animals. Focusing resources where they are needed most could help improve animal welfare in institutions that lack resources or have not proven their ability to comply with the AWA and its regulations, he said. -he declares.
He and his counterparts at other research institutions have known for years that APHIS can conduct targeted inspections in any of the three areas regulated by the AWA: animals, facilities, or records. The two most recent inspections of its AWA-related facilities were both focused, the first on animals and the second on records.
Dr Leland also said that targeted inspections could allow APHIS officials to delve into certain aspects of a facility, rather than taking a general look at all the activities regulated by the AWA during each inspection.
When asked if targeted inspections were a good policy, Dr Leland said he would wait to see data from the agency that would allow for comparisons over several years in terms of violations found and citations issued. Finding a similar number of violations and citations would suggest that the inspection system at least meets the quality of the previous system, he said, although he acknowledged that other variables could affect those numbers.
The Science article and a related announcement from the Harvard Law School Animal Law & Policy Clinic both suggest that APHIS officials adopted the policy without a public announcement, meaning the public may not have been aware of the change. A legal clinic researcher discovered the policy in documents obtained through a public records request filed on behalf of two advocacy organizations, Rise for Animals and Animal Legal Defense Fund.
Still, Dr. Donna Matthews Jarrell, president of the American College of Laboratory Animal Medicine, said in a statement that ACLAM leaders and other members of the laboratory animal community were aware of the changes in the USDA policy and that these changes had been a major discussion. at meetings, rallies and webinars in 2019. She noted that discussions at one of those meetings, the annual Public Accountability in Medicine and Animal Care and Use Conference, included discussions on the topic that were open to the public.