Question III.D.2.: Potential for Pain and Distress
As part of their enforcement of the Animal Welfare Act (AWA), the USDA requires that "procedures involving animals will avoid or minimize discomfort, distress, or pain". When procedures will be used that may reasonably be expected to cause more than momentary or slight pain or distress, USDA requires that investigators prove they have considered alternatives that may replace, reduce, or refine animal use for AWA-covered species. Question III.D.2. is included on the AUP form to determine if we must ask you to document this search for alternatives. The difficulty in answering this question comes from determining whether a procedure has the potential to cause more than momentary or slight pain or distress. USDA has given us some guidelines in their Policy 11, and ULACC has settled on the following interpretation, which it applies to all vertebrate animals, not just AWA-covered species. These examples have been adopted from Policy 11 and a document originally produced by the Canadian Council on Animal Care.
Answering Question III.D.2
NO: domestic animals maintained in simulated or actual commercial production systems, routine maintenance such as cage cleaning or animal transfer, blood sample collection with local anesthesia as needed, ultrasound examination, injection of nonpathogenic or nontoxic substances, routine anesthesia, physical examination, tissue collection after euthanasia, routine biopsies under anesthesia, short periods of restraint beyond those required for physical examination, short periods of food or water deprivation not exceeding deprivation in nature, use of noxious stimuli from which escape is possible, observational studies of animals in their natural setting, AVMA-approved methods of rapid euthanasia, cannulation or catheterization of blood vessels with local anesthesia, laparoscopy with local anesthesia.
YES, but relieved through proper analgesics: survival surgery (even with no complications), terminal surgery, use of Freunds complete adjuvant, ocular or skin irritancy testing with analgesics, ascites production in mice with distention not to exceed that of normal pregnancy, tumor implantation with early endpoints (no ulceration, noninvasive, no impact on health and well-being), intrathoracic or intracardiac injection and sampling under anesthesia, short periods of food or water deprivation exceeding deprivation in nature, and the slight potential for illness, debilitation, or incapacitation in a small percentage of experimental animals (which can be treated or relieved).
USDA requires an alternatives search for these procedures.
YES, but no anesthetics or analgesics: prolonged food or water deprivation, prolonged immobilization, immobility or paralysis in a conscious animal, surgery with muscle relaxants but not anesthetics, methods of euthanasia not approved by the American Veterinary Medical Association, noxious electrical shock, death as an endpoint, inescapable noxious stimuli, unrelieved major stressors such as maternal deprivation or conspecific aggression, toxicity studies without analgesia, excessive tumor burdens, clinical disease which must be allowed to progress to a moribund stage, LD50 studies, burn or trauma infliction in unanesthetized animals.
USDA requires an alternatives search for these procedures, and the numbers of animals used in these procedures must be reported annually to USDA. Additionally, use of these procedures must be scientifically justified in Section III.D.1.

