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Response or Comment

Publication Date



We conclude from the analysis that the Reporting System, as presently administered, fails to achieve its primary statutory objective: it does not provide APHIS with information sufficient to demonstrate that researchers have used pain-relieving drugs "appropriately" and in accordance with "professionally acceptable standards." The chief reasons for this failing are (1) regulations and guidelines do not define "pain" or "distress," (2) regulations and guidelines do not adequately define "routine procedures," and (3) regulations and guidelines do not require meaningful explanations for the withholding of pain-relieving drugs in procedures acknowledged to cause pain.


This article is adapted from a petition for rulemaking filed by The HSUS with the USDA on February 22, 1982.