Accreditation by the Association for the Assessment and Accreditation of Laboratory Animal Care, International (AAALAC) is voluntary, expensive, and not mandated by any federal law. Accreditation requirements cover all animals used for research and include compliance with the Guide and with the federal Animal Welfare Act. Typically, accredited laboratories maintain better facilities and animal care because they have more resources at their disposal. This is not always the case, since the downfall of this system is that compliance is left to the individual institutions (except for paperwork reporting and announced site visits conducted by AAALAC once every three years), and the majority of facilities conducting experimentation are not accredited.

USDA’s role is critical as the sole agency enforcing minimum standards of laboratory animal care. The Animal Welfare Act (AWA) covers all warm-blooded species and is enforced by the U.S. Department of Agriculture through unannounced inspections conducted at least once each year and reports from the institutions to USDA. The standards are modest (including basic care, feeding, watering, and prevention of unnecessary pain when possible), but assure good animal care and, as a result of the good animal care, better science.

Rats, mice, and birds used for experimentation were excluded from the regulations for the enforcement of the AWA because of financial limitations only. The intent of Congress in its 1970 amendment to the AWA was to apply the modest requirements of the AWA to all warm-blooded species.

The proponents of inclusion of rats, mice and birds in the regulations for enforcement of the Animal Welfare Act are not recommending requirements for the housing and care of these animals that are out of line with those already contained in the Guide. Further, in the interest of ensuring congruence between USDA and NIH, the 1985 amendment to the AWA included language specifically mandating the Secretary of Agriculture to consult with the Secretary of Health and Human Services prior to issuance of regulations.

The impact on animal experimentation of inclusion of rats, mice and birds under the Animal Welfare Act should be negligible. Institutions already in conformance with the Guide and/or accredited by AAALAC would likely already be in compliance with any new regulations promulgated by USDA. The only facilities which would be impacted are those which maintain rats, mice, and birds under filthy conditions without proper housing, food, water, care, and oversight. The animals at these facilities will benefit from new USDA regulations, and as a result the scientific results obtained will be vastly improved, too. (Although unable to take enforcement action, there have been USDA inspectors who have noted problems with the care of rats and mice at some NIH grantee institutions and AAALAC-accredited facilities.) USDA jurisdiction over all research facilities using birds, rats, and mice is needed because historically, it has been USDA, not NIH or AAALAC, that has discovered animals in egregious conditions.