published my estimate of over 110 million mice annually in US labs and got some criticism of my methods and the resulting estimate. Fair enough. So let’s suppose there are “only” some 30 or 50 million per year. What should we do with that info? 

Two opposite conclusions from seeing these large numbers:

This is too many animals to leave out of the federal protections of the US Animal Welfare Act (AWA)

This is too many animals for the USDA ever to be able to extend AWA protections to

As I said in my article, the truly large number of mice in labs should make us ask whether they should become “animals” in the US Animal Welfare Act. I say Yes; others say No.

Knowing my concern that Congress has said that mice are not “animals” in the eyes of the Animal Welfare Act, told David Grimm two more-or-less opposite reasons for keeping things as they are:

  1. Speaking of Research “disagrees with the idea that the animals are at risk of being mistreated because they are not covered by the AWA… that all labs that receive federal funding must answer to institutional animal care and use committees, which follow the three Rs and oversee the welfare of all lab animals. Those that don’t receive federal funds typically submit to AAALAC inspections,… It is unlikely that there are large number of facilities that are uncovered by any regulation.”
  • Except, according to the National Association for Biomedical Research, it would do something. Maybe that something would not improve these animals’ welfare, but the government would not “have the time or money to track so many animals, and that doing so would drain vital resources. Now is not the time to be seeking additional restrictions on biomedical research or endeavoring to make it more difficult and more expensive.” 
  1. To the first point, I agree (anecdotal experience and informal communication) that accreditation site visits are really quite rigorous and helpful. I don’t see that accreditation alone, without AWA inspections, is sufficient (see below).  As for their claim that it is unlikely that there are large number of facilities that are uncovered by any regulation — first, nobody knows how many [ SoR estimates 10 – 25 million, which is highly implausible, so I’m not sure I buy their other estimates]. Second, perhaps we should worry that there are labs with no regulatory oversight and that are not accredited [I certainly know of several] and why should we be confident in the quality of their animal care?
  1. On the second point, I agree that the USDA’s resources would be stretched if they upped their game to covering the other 99% of mammals in labs. From the point of view of the inspected, again, I’m not convinced. Places that have NIH regulations to follow and/or are already accredited are already doing committee reviews and annual reports, which is what AWA coverage would require. Places that aren’t, should be, and AWA coverage would make that happen.   

So, are current welfare protections good enough for mice?

I say “no,” for four main reasons:

  • There is close to zero public transparency about mouse use
  • There are many labs (No One Knows how many, because only the AWA that excludes them requires publicly reporting animal numbers) that are not accredited and are not under jurisdiction of NIH animal welfare laws and 
  • It is impossible to monitor trends in animal use, including in painful experiments, without sound publicly-available statistics
  • There’s nothing like an unannounced USDA inspection to keep people on their toes.

What to do? 

Well, it will take an act of Congress, quite literally, for mice to become Animal Welfare Act animals. That will not happen. American politics is a bit of a mess now, eh? Still there should be a system in which these animals at least occasionally receive the kind of spot-checks from government veterinary animal welfare inspectors that hamsters get.

The NIH could certainly commit to greater transparency, for that fraction (half? fewer? more?) of lab mice under NIH jurisdiction. They could add up the numbers of animals reported to them annually and post that, as USDA does for Animal Welfare Act-covered animals. They could (with resources they don’t presently have) do more site visits and make their findings public (you can get them, but only via FOIA requests).

Meanwhile, many good people are working on ways to make laboratory life better for our most important and numerous animals, if only their efforts can trickle up to administrators who know their institution can escape scrutiny of much of their animal research.  

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