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US-centric: Animal Welfare Law Changes?

ceph

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3. The argument that regulations will make our work harder is a straw man, in my opinion. Everyone who works with any animal should be doing good science - not only investigating relevant questions, but applying similarly regulatory standards to themselves de facto as would be required by IACUC rules. All of us should already be asking 'how many animals?' 'are the animals relieved from unnecessary stress?' and 'can I do this better?' as a matter of course. So having to go the extra step of getting it approved should not be particularly onerous. Regulations should only improve the science we do.

In spirit, I'm with you. Additionally, I think a discussion on ethics for all animals is timely. On top of that, I politically believe that the US needs more regulators to protect consumers from bankers and other to big to fail companies with deep pockets. So I'm generally for regulation and oversight.

However, I have had a number of experiences where what actually happened and what should have happened were very different.

Example 1: Importing cuttlefish into Canada was no problem. They have the word "fish" in their name and import permits were quickly approved - seriously. This is for Sepia officinalis which might just live if it somehow escaped. . . Importing tropical octopuses into Canada was a very different beast - while also cephalopods, they do not have the word "fish" in their common name so the permit request went to go a different branch . . . which had different rules resulted in having to keep them in full Quarantine under lock and key, incinerate and report each and every one that died, kill(!!!) all animals at the end of the experiments, use an iodine bath that stained my hands and a foot bath and fill out regular paper work. This is for a tropical species of cephalopod - it and its parasites would have a very hard time in cold Canadian waters. I have and had ethical concerns with this oversight, even more so given the inconsistency between the two cephalopod species and the requirement to kill at the end.

Example 2: I once was detained for over an hour because I failed to declare an Ammonite fossil as plant or animal material. I declared it, just not as a plant or animal. . . BECAUSE IT IS A ROCK. Apparently the agent though it was some sort of bio-hazard. . .

Example 3: Our lab at Dal was breeding scallops and putting their larvae on a space shuttle mission. One year we had 2 different animal care groups come inspect us. Like most inspections of this nature, we had advanced warning and we asked around to find out what the inspectors were looking for. The first group was from industry - we cleaned up the lab a bit but otherwise didn't do much for them. They were very impressed with our facility, our bio-filters and our healthy brood stock that produced offspring like clockwork. The second group was academic and included medical doctors and mammal people; to them "sterile" was the gold standard. So we bleached the tanks, pipes and everything and gave them exactly what they wanted. They were also very impressed and commented that most marine labs were much dirtier with scum in their tanks while ours were so nice and clean. After that cleaning and inspection, it took 6 months before the scallops would breed again. . . which is a problem if you are trying to hit the space shuttles schedule.

Example 4: In Bermuda I had a tank of bioluminescent worms. The tanks was clearly labeled but if you looked in it, it looked more or less empty as the worms were small and lived in tubes made out of detritus. Prior to an animal care inspection, someone "cleaned" my tank and killed my animals. Death by animal care oversight strikes again!

I am not arguing against regulation - but I am suggesting that we be very careful with it. Clearly, it can be beneficial. But in my experience it can also make more work and it can and does kill animals needlessly - the exact opposite of the intended effect. This is especially true when non-specialists are making assessments or decisions well outside of their field or are applying standards from one field to another where they are simply inappropriate. The reality is, very few people have knowledge of marine invertebrates and know what is and is not appropriate. Hopefully that will change.



James
 

gjbarord

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How did I miss this thread?

I will have to agree with Rich. Why are these regulations warranted? Are there scientists and institutions doing some off the wall experiments? Or aquariums caring for their cephalopods poorly? Regulations need to be based off of sound reasoning and at this point, it appears that there is no just cause for some of the regulations being discussed.

Simply being "proactive" is not always a legitimate reason to bog down process with regulations.

I would really like to see the logic behind all of the regulations before implementing anything.

Greg
 

robyn

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James, legislation can't fix stupidity!! :wink: Each of the examples you provide (my favorite is the one about the fossil....) seem more to be evidence that in the absence of any common standards of acceptable practice, individuals will act in ways that they think are best, and at times make (understandable) errors. Yes, double-standards are a problem, but one of my arguments is that regulations help prevent personal, uninformed decisions that might be harmful to the animals.

More generally:

I think it's worth noting that the primary intention of most IACUC regulations is to facilitate, not hobble, research - to ensure that research - if it's going to be done at all - is conducted on healthy, appropriately housed and properly husbanded animals. They are usually staffed primarily by scientists, veterinarians and one or two non-scientific outsiders. They are not anti-research.

As to Greg's question: Why are these regulations warranted? Are there scientists and institutions doing some off the wall experiments? Or aquariums caring for their cephalopods poorly? I personally have seen octopuses (bimacs and briareus, mature size) supposedly being used for 'learning' experiments that were housed in completely bare 12"x12"x12' plexiglass boxes, without any shelters, little room to move and under constant bright lighting with no shielding from people walking past - not overtly inhumane or cruel, but almost certainly stressful, boring and suboptimal. It is well established that for rodents, a properly enriched and appropriately appointed cage makes for not only better results, but happier animals. For octopuses, why not require the same standards? (for toxic species, different housing is of course necessary to balance the need to keep researchers safe - this is something that IACUCs regularly account for with vertebrate disease-models). If your experiment for whatever reason needs isolation, sensory deprivation, stress, pain etc., and you have valid reason for doing that to your subjects, it is the job of the impartial IACUC committee to see to it that an appropriate balance between individual welfare and overall benefits are optimised. Why argue with that?

The concern, often expressed, that the people on these committees are not well enough informed to make a correct decision on the value of the study or on what is best for the animal, can usually be overcome by in-person discussions between researchers and the panel. A related misconception I see growing in these discussions is that "The Government" somehow oversees the approval process for each study. This is, of course, not the case. The 'government' will appoint some body to devise the regulations, most likely made up of scientists at the NSF or NIH, and follow what they recommend. Not that scientists can't also do a crappy job of writing recommendations, of course... Once the recommendations are legislated, each institution uses it's own approval committee that is charged with applying those regulations.
In institutions with researchers working on inverts, those committees are going to be staffed with people familiar with invertebrate animals. It's not some random be-suited guy wearing a donkey or elephant pin, in an office in Washington, whose going to refuse to approve your application.

Note that all my focus here is on research settings, not hobbyists or private keepers. General animal welfare laws are an entirely separate beast from research animal welfare laws. (Can anyone confirm that the EU directive does not cover private owners?).

Of course, the main issue to me is that the EU has applied its directive in the absence of any data concerning pain or suffering in cephalopods. The reference they cite for evidence of 'pain sensation' is a review article that does not provide empirical evidence of this. If regulations are to be drafted, let us at least have some scientific evidence on which to ground them.
 

ceph

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robyn;183277 said:
I personally have seen octopuses (bimacs and briareus, mature size) supposedly being used for 'learning' experiments that were housed in completely bare 12"x12"x12' plexiglass boxes, without any shelters, little room to move and under constant bright lighting

I have reviewed a paper on a different species of cephalopod that used somewhat similar methods. For behavioral studies such conditions are not appropriate and are very likely to negatively impact the results. It is not perfect, but we do have a peer review system that generally weeds out poor science.

Other people have different definitions of research and science. To many, research is looking something up on wikipedia. To some, science is proposing that a hypothetical squid arranged bones in a self portrait millions of years ago. . . It can't be disproved so it must be science. A dolphin show I watched made a big deal of their science as well - what do they do? They take blood samples every quarter and send them to the vet. All of these are valid definitions of research and science - but they are not what a scientist generally means by the words research and science.

Was the work mentioned above published? Did it pass peer review? Was it even submitted for publication? If you want to talk about science to scientists, peer review is the standard. I suspect the octopus "research" example you mentioned was closer to the "research" at the dolphin show I was dragged to. Perhaps I am wrong.

robyn;183277 said:
The concern, often expressed, that the people on these committees are not well enough informed to make a correct decision. . . the government. . .

I started out doing everything by the book and have learned to be concerned. I believe the examples listed above validate that concern - animals died needlessly. Yes the committee members are often scientists, good people, well meaning and experts in their field but most animal science is conducted on vertebrates which have substantially different life history and need very different life support systems. Look at any issue of animal behavior and examine the percentage of papers on invertebrates and compare it to the 95%+ of invertebrates that inhabit the planet. Well meaning scientists that work on rats can't be expected to know the basics of the nitrogen cycle or why the "ugly scum" on the tank is critical to life support. In practice, most scientists give the committee what they want (bleach the tank, incinerate the animals) rather than being the nail that sticks up and risk a confrontation which can completely shutter their research or brand them as unethically treating animals. The risk may be low, but the downside isn't.

DFO is the government in Canada. And they sent the cuttleFISH import permits requests to one group of experts and the octopus requests to another group of experts with very different results as noted above. The TSA employee I mentioned was also a govt worker. In that example I'm talking about being able to distinguish the difference between a living thing and a rock! It was the deputy director, a molecular biologist, that game the orders to clean the wet lab prior to an animal care inspection that resulted in killing my bioluminescent worms. Customs agents and Fish and Wildlife have good people working for them but often do not have the expertise to identify many of the diversity of animals that they encounter as well.

I do have serious concerns. I have leaned to have those concerns though experience. These concerns need to be part of the dialog.

In the peer review system that we have now, work is reviewed by colleagues in the same field. International colleagues that have the specialist knowledge needed to make informed decisions about the science being conducted. It isn't a perfect system, and it won't stop entertainment claiming to be science, but the level of competence and specialized knowledge is very high.
 

robyn

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I suspect the octopus "research" example you mentioned was closer to the "research" at the dolphin show I was dragged to. Perhaps I am wrong.
No, it was at a university, in the lab of someone that had worked with cephalopods for quite a while, but wasn't overly concerned with welfare.

In the peer review system that we have now, work is reviewed by colleagues in the same field. International colleagues that have the specialist knowledge needed to make informed decisions about the science being conducted. It isn't a perfect system, and it won't stop entertainment claiming to be science, but the level of competence and specialized knowledge is very high.

Sure, I agree peer review is the gold standard for catching bad research. After it's been done. After the animals lived out their s****y lives in a glass box and after it was clear that the research hours and dollars and the cost of the animals' wellbeing were worthless. An IACUC's job is to see to it that doesn't happen before the research begins. I think that's better.

Having both is the ideal, in my opinion.
 

ceph

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Good and valid points Robyn.

As someone who is concerned with animal welfare, I remain somewhat skeptical. Animals in my care have died needlessly due to oversight by non-specialists and/or prep for inspections. This has happened more than once. It happens to others. We usually don't talk about it as it isn't good to be the nail that sticks up.

Hopefully we can find a middle ground where it isn't a free for all for invertebrates like cephalopods and animal care committees reviewing marine systems have at least a few members with specialist knowledge.
 

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