We can all sympathize with Hendricks. Often we follow a set of instructions to the 'T' but still feel that we end up with egg on our face. In my opinion, the system worked and could only be improved by providing more training on the recognition of pain and appropriate responses. Although I have no doubt that Hendricks is not being punished or picked on, without further clarification by the Great Eastern IACUC, he may have a valid classification question worth considering.
Let's assume the few animals in question experienced unrelieved pain longer than “momentary” or greater than “minor.” Do any laws, policies or instructions indicate that we should report such animals in category E? The answer is maybe. Unfortunately, the policies and instructions explaining how to classify animals into column E are not found in one single document. Additionally, policies and instructions are revised sporadically for clarification. The reporting requirement for USDA-covered species originates in the Animal Welfare Act (AWA), section 2.36 (ref. 1). The wording in the AWA is very similar to that found on APHIS Form 7023, used by research facilities for their yearly report. Later, Policy 17 was written to further clarify annual reporting2. Policy 17, as originally written or later revised, did not tinker with what seems to be a clear identification of which animals should be included in column E of Form 7023. To my knowledge, there are no other specific instructions originating from the USDA regarding annual reports. Considering the tenor of the regulations above, I can understand Hendricks' position.
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