The following statement from CAAT's Board appears on their website at: (http://caat.jhsph.edu/issues/ab-ratsmicebirds.htm)

Issues Advisory Board Statement on Rats, Mice, and Birds (12/4/01)

This statement represents the viewpoint of members of the CAAT Advisory Board as individuals. It does not reflect the official position or opinions of The Johns Hopkins University, the sponsoring organizations of CAAT, or of any other institution to which individual members may belong.

Rats, mice, and birds account for about 90% of all laboratory animals in the United States. And yet these animals -- upon whom we rely so heavily in our biomedical research and product safety testing -- are not covered by regulations designed to enforce the Animal Welfare Act (AWA), the principal law governing the care and treatment of research animals in this country. The Advisory Board of the Johns Hopkins Center for Alternatives to Animal Testing (CAAT) finds this situation untenable.

The law itself does not exclude rats, mice, and birds. Rather, a ruling by the Secretary of Agriculture excluded them from regulation under the AWA. A 1970 amendment to the original 1966 Act defines the term "animal" to include dogs, cats, nonhuman primates, guinea pigs, hamsters, rabbits, "or such other warm-blooded animal." USDA regulations, however, specifically exclude "birds, rats of the genus Rattus, and mice of the genus Mus bred for use in research" in their definition. The regulations do cover wild-caught mice or rats. They cover other small rodents, such as hamsters, gerbils and guinea pigs. But they do not cover the rats and mice that do the lion's share of lab duty.

The CAAT Board sees no scientific or ethical basis for this exclusion.

The Board firmly believes that animal research should be guided by The Principles of Humane Experimental Technique as described by Russell and Burch -- i.e., the Three R's of reduction, replacement, and refinement. These principles should apply as much to rats, mice, and birds as to other laboratory animals. But without regulation under the AWA, they are not necessarily applied equally.

Clearly, not all animal use can be replaced by non-animal methods. The numbers of animals can be reduced, however, and experimental methods refined to minimize pain and distress for the animals. Oversight by the USDA under the AWA can help achieve both reduction and refinement. Currently, research institutions must report annually to the USDA on their use of animals regulated by the AWA. Rats, mice, and birds are excluded. Without a reliable accounting of these animals, there is no way to monitor progress in reducing their numbers.

The AWA serves to promote refinement in several ways: it spells out certain requirements for the humane care and treatment of animals; it requires investigators to search for alternatives to procedures that may be painful or distressful to the animals, and it stipulates that Institutional Care and Use Committees (IACUCs) must review experimental protocols involving animal use.

Again, rats, mice, and birds are excluded.

The CAAT Board recognizes that the majority of laboratory-bred rats, mice and birds in the United States are in facilities that already meet or exceed AWA standards. Investigators who receive federal funding are governed by Public Health Services Guidelines. Further oversight is provided if the institution is AAALAC accredited.

The Board also recognizes that there are a number of issues that must be addressed in implementing the inclusion of these species under the AWA. In particular, the CAAT Board is concerned that everything possible be done to ensure that the inclusion of rats, mice, and birds does not detract from

enforcement of the AWA for the animals already regulated and that the regulatory burden be no greater than that already applied to other rodent species. The Board also supports efforts to explore ways to further reduce regulatory burden consistent with the assurance of animal welfare.

Alan M. Goldberg, CAAT director, for the Advisory Board

Gabriela Adam-Rodwell, Ph.D. (Mary Kay Holding Company)

Larry S. Andrews, Ph.D. (Rohm & Haas Company)

Angela E. Auletta*, Ph.D. (U.S. Environmental Protection Agency)

Frank W. Baker, Ph.D. (Procter & Gamble Company)

Myra O. Barker, Ph.D. (Mary Kay Holding Company)

Rebecca Bascom, M.D., M.P.H. (Penn State University)

John L. Butenhoff, Ph.D. (3M)

William E. Dressler, Ph.D. (Bristol-Myers Squibb Company)

James Foster (Charles River Laboratories, Inc.)

James J. Freeman, Ph.D. (ExxonMobil Biomedical Sciences, Inc.)

A. Jay Gandolfi, Ph.D. (University of Arizona)

Alan M. Goldberg, Ph.D., D.Sc.Hc. (Johns Hopkins University)

A. Wallace Hayes, Ph.D. (The Gillette Company)

Herman B.W.M. Koëter, Dr.Tox. (Organization for Economic Cooperation and Development)

Rick Main, M.S., M.P.H. (Alberto-Culver Company)

James P. McCulley, MD (University of Texas)

Kenneth S. Ramos, Ph.D. (Texas A&M University)

Bernard Robaire, Ph.D. (McGill University)

Noel R. Rose, M.D., Ph.D. (Johns Hopkins University)

Andrew N. Rowan, D.Phil. (Humane Society of the United States)

Daniel N. Sauder, M.D., FRCPC (Johns Hopkins University)

Leonard M. Schechtman*, Ph.D. (U.S. Food and Drug Administration)

Steven A. Shaya, Ph.D. (Johnson & Johnson)

William S. Stokes*, D.V.M. (National Institute of Environmental Health Sciences)

Gihan I. Tennekoon, M.B.B.S., LRCP (University of Pennsylvania)

Eve Lloyd Thompson (Bernice Barbour Foundation, Inc.)