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US-centric: Animal Welfare Law Changes?

Joined
Apr 19, 2010
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478
Let's have a poll.

A lot of changes have been made to laws overseas to allow for the inclusion of some invertebrates in animal welfare laws, but not in the United States.

Currently, invertebrates are not protected for any purpose whatsoever. They are at the mercy of the individuals using them, or the IACUCs overseeing the study if it is research. Correct me if I'm totally wrong.

What do you think should be done regarding the current status of invertebrates in law, and why?
 
Just to clarify, IACUC regulation does not include any cephalopods at the time, therefore there is no requirement for approval of a proposed study on cephalopods.

Also to clarify, the EU directive will be in effect starting January 1st, 2013. Suzanna Luhimies represented the EU's view at Euroceph and you can see her presentation here. It's a great place to start reading about what kind of changes will take place in 2013.

Here are some points that concern me the most. The EU Directive 2010/63/EU will enforce:

- "Systematic ethical evaluation," "transparency," and "better enforcement" "resulting in more humane treatment of the animals and improved science" (Louhimies, 2011). This implies that teuthologists working in the EU are a priori (1) unethical and (2) incompetent, therefore there is a need to enforce laws to improve research and welfare. No evidence is provided whatsoever on how the European Committee came to this conclusion.

- Populations of "purpose bred animals" to Reduce the amount of wild cephalopods caught specifically for research. Some species (example, O. vulgaris) are notoriously difficult to be raised in captivity, because of the difficulty, for example, of reproducing a suitable environment for the pelagic phase of their development. This excludes some species from being studied due to inability to provide a sustainable population specifically for research. However, even when specific species allow for captive breeding, there are several factors (Forsythe, DeRusha and Hanlon, 1994) that may decrease external validity of findings on the behavior of captive bred subjects.

- Reduce "Signs of pain suffering, distress and lasting harm" during procedures. Again, the EU infers that cephalopods have pain perception without providing even a single experimental finding to prove it. It has been discussed before in the forum and others have said it better already.

For those of us who have attended this workshop at Napoli, it was clear that the reasons stated here are means to enforce uniform laws around Europe rather than evidence to support necessity for them. The EU representative at some point tried to defend the need for the Directive by saying that (1) UK has higher scientific standards than other countries, (2) certain countries members of the EU are allowed more flexibility to work with than others and (3) the rest of these countries complain about the non-uniformity of enforcement to the EU, therefore (4) everyone should model the UK standards. This is the general idea that was given at the meeting and not in the actual article. Personally, I think this is ridiculous, but then again I do not work in that area to know.

For these reasons, I say let's stay away from laws, keep the power to the unethical and incompetent teuthologists!

References:

Forsythe, J. W., DeRusha, R. H. & Hanlon, R. T. 1994 Growth, reproduction and life span of Sepia officinalis Cephalopoda: Mollusca cultured through seven consecutive generations. J. Zool. 233, 175-192.

Luhimies S. Revised EU legislation on the protection of animals used for scientific purposes Directive 2010/63/EU Euroceph, Naples April, 2011. Unpublished conference proceedings.
 
I want to vote for "give them protection, but not as much as invertebrates", but chose "I'll articulate" because I'd like to see it START small and evolve as appropriate. Not sure whether they wouldn't end up having more protections than some vertebrates, in the end-state.

Great poll NB! Props to you again BTW for moderating a very interesting cephalopod ethics discussion at TONMOCON IV (thus inspiring this forum). THANKS! :notworth:
 
Stavros;182864 said:
Just to clarify, IACUC regulation does not include any cephalopods at the time, therefore there is no requirement for approval of a proposed study on cephalopods.

Also to clarify, the EU directive will be in effect starting January 1st, 2013. Suzanna Luhimies represented the EU's view at Euroceph and you can see her presentation here. It's a great place to start reading about what kind of changes will take place in 2013.

Here are some points that concern me the most. The EU Directive 2010/63/EU will enforce:

- "Systematic ethical evaluation," "transpareny," and "better enforcement" "resulting in more humane treatment of the animals and improved science" (Louhimies, 2011). This implies that teuthologists working in the EU are a priori (1) unethical and (2) incompetent, therefore there is a need to enforce laws to improve research and welfare. No evidence is provided whatsoever on how the European Committee came to this conclusion.

Can you explain how this implies that all teuthologists are a priori unethical and incompetent? My understanding is that most users of vertebrates, which are covered by animal welfare regulations, are in fact ethical and competent, but that these laws are in place because even unintentionally there can be problems with procedures being potentially inhumane to the animal and to set standards of maintenance and housing that can be used as a benchmark to assess whether animals are being kept in good conditions. This, of course, necessitates that teuthologists have input on what constitutes inhumane treatment, but that's another issue.

- Populations of "purpose bred animals" to Reduce the amount of wild cephalopods caught specifically for research. Some species (example, O. vulgaris) are notoriously difficult to be raised in captivity, because of the difficulty, for example, of reproducing a suitable environment for the pelagic phase of their development. This excludes some species from being studied due to inability to provide a sustainable population specifically for research. However, even when specific species allow for captive breeding, there are several factors (Forsythe, DeRusha and Hanlon, 1994) that may decrease external validity of findings on the behavior of captive bred subjects.

I mentioned this in another thread, but is there no way we could perhaps phase out O. vulgaris for some purposes and bring in another octopus species which is more easily reared in captivity, such as O. bimaculoides? Bimacs are less well studied, but how much work do we have to do to establish a new 'default'? Also, certainly there is an issue with captive-bred subjects instead of wild-caught subjects, but then how do you suppose researchers get along with captive-bred mice and rats instead of wild-caught mice and rats for behavior trials (though I suppose in many cases, they're assessing their function as a general mammalian model rather than mouse and rat behavior specifically)?

- Reduce "Signs of pain suffering, distress and lasting harm" during procedures. Again, the EU infers that cephalopods have pain perception without providing even a single experimental finding to prove it. It has been discussed before in the forum and others have said it better already.

My understanding of the topic is that they secrete a number of compounds that mammals also secrete when they undergo pain perception. Of course, that does not mean that they have any more sophisticated response than nociception, but do they react to the stimulus such that they develop a long-term aversion to it or show responses such as color changing or lassitude? Have we tested pain perception on the mantle as opposed to the arms? I prefer to err on the side of caution, anyway, lest I find out some time in the future that I have unwittingly tortured an animal.
 
Before I can get behind regulations, I want to know the problem that they are supposed to be fixing. If there is no problem, nothing needs to happen. What problem would this thought experiment law address?
 
I am firmly in favour of regulations governing the use of cephalopods in research. In theory, such regulations would have a direct impact on my own research, since I am one of the few people actively investigating the 'pain' question in cephalopods. However, my reasoning for support is as follows.

1. Regulations place all of us - researchers, institutions, IACUCs, funding bodies and journal editors - on the same page. If we all have a common, agreed standard to which any study is held, it prevents individuals at any of these places imposing their own personal views on others regarding 'acceptability' and 'value' of our work. I'm already acquainted with the problems caused by this lack of standardisation, and I'd love for it not to be an issue in future.

2. The presence of regulations to which we all must adhere makes any incompetence or dodgy ethical standards objectively measurable, avoiding victimisation or marginalisation of any group of researchers.

3. The argument that regulations will make our work harder is a straw man, in my opinion. Everyone who works with any animal should be doing good science - not only investigating relevant questions, but applying similarly regulatory standards to themselves de facto as would be required by IACUC rules. All of us should already be asking 'how many animals?' 'are the animals relieved from unnecessary stress?' and 'can I do this better?' as a matter of course. So having to go the extra step of getting it approved should not be particularly onerous. Regulations should only improve the science we do.

4. Regulations legitimise research such that our institutions are now officially, legally a party to the research we do. Which means that should our work be exposed to public or activist scrutiny, we have the institution already on-side and tacitly supporting our work. This is extremely important for those of us who work on pain, or who use invasive or lethal methods in our research.

5. Regulating the use of some or all invertebrates under the same laws covering vertebrates makes a fallacy out of the 'replace' requirement that is one of the current requirements (the 'Three R's' - replace (with 'less sentient' or 'lower' animals) -- 'refine' and 'reduce are the others). I strongly object to the philosophy that all inverts are somehow 'less' than all vertebrates, and that it follows that their subjective experience can be discarded in our considerations of ethics. Changing the law to include some or all inverts invalidates this tenet. I'd be very, very happy to see that change.
 
neurobadger: The short and dirty answer to your questions (I will expand my answers later) is that the problem here is not about having guidelines to take care of the animals and such, which is a welcomed notion.

My biggest problem is government regulating anything in general and science more importantly, and second, it's all based on unfounded inferences. They claim we need to have this law because there is a possibility we might not be ethically evaluating reliably enough current procedures, that there might not be transparency and that we might not be having the best humane treatment and scientific standards as is.

How did they come to this conclusion? By what measure do they infer workers are not ethical enough and that they have lower scientific standards? What exactly is the problem they are trying to solve in the first place? That's why I see this that they claim teuthologists are unethical and incompetent workers.

I will come back to this later.
 
Stavros;182877 said:
My biggest problem is government regulating anything in general and science more importantly, and second, it's all based on unfounded inferences. They claim we need to have this law because there is a possibility we might not be ethically evaluating reliably enough current procedures, that there might not be transparency and that we might not be having the best humane treatment and scientific standards as is.

How did they come to this conclusion? By what measure do they infer workers are not ethical enough and that they have lower scientific standards? What exactly is the problem they are trying to solve in the first place? That's why I see this that they claim teuthologists are unethical and incompetent workers.

The question of regulation of anything is enough of a giant barrel of worms (suffice to say I do not agree with you regarding government regulation of things) and this is not an appropriate forum in which to address it, but I can say with some certainty that current animal welfare regulations - at the NIH, at least, where I have a family member - are quite emphatically not based on unfounded inferences (I mention in particular the book Recognition and Alleviation of Pain in Laboratory Animals and Guidelines for the Care and Use of Mammals in Neuroscience and Behavioral Research). I am somewhat inclined to believe, though I may be too idealistic here, that if NIH, the USDA, and other governmental bodies in the United States brought their resources to bear on this and voiced interest in adding some invertebrates to protected species, things would get done with a lot more care than how they were done in the EU. Our politicians may be a lost cause, but do not dismiss their underlings.

I agree entirely with Robyn that well-designed regulations are not only necessary but should, if you are actually doing good science, not change a darned thing about a person's research. They weed out the chaff from the wheat.

And just because most workers are ethical does not mean all of them are. Last I heard the bodies that deal with noncompliance toward these regulations are still pretty busy. And what's wrong with ethical evaluation and transparency?
 
neurobadger;182866 said:
And just because most workers are ethical does not mean all of them are.
Just because there is a law, these few you mention here won't become more ethical. Science will never be safe from bias and cheating just because there are laws, peer review bodies and so on. These will help reduce it yes, but they are far from reducing it to the point that we want to believe. At the end of the day, the responsibility lies with you in the first place, not because there is a law that enforces it.

neurobadger;182866 said:
Last I heard the bodies that deal with noncompliance toward these regulations are still pretty busy. And what's wrong with ethical evaluation and transparency?

I think you misunderstand me on this. Read the sentence again; the claim made is that ethical evaluations and transparency are needed, implying that they are missing in the first place, and enforcing them will allow for more humane treatment and improved science, implying that there have been lower standards again in the first place.

As far as I'm concerned, actions but not intentions make a worker competent. If you unintentionally use procedures that harm an animal then you need more training. No regulation will help you with sloppiness even if your procedures are approved by a set body. And before we can argue that a regulation will provide more training, we have to be realistic here and say that you won't go ahead in this career if you don't have solid training anyway.

As far as the guidelines go on mammal care, we can't just take them and apply them to inverts. Pain recognition in mammals is one way to go towards finding evidence in inverts lets say, but you can't regulate research due to cephalopods feeling pain, before anyone gets to study it. In that sense, the EU has jumped the gun here.

I mentioned this in another thread, but is there no way we could perhaps phase out O. vulgaris for some purposes and bring in another octopus species which is more easily reared in captivity, such as O. bimaculoides? Bimacs are less well studied, but how much work do we have to do to establish a new 'default'? Also, certainly there is an issue with captive-bred subjects instead of wild-caught subjects, but then how do you suppose researchers get along with captive-bred mice and rats instead of wild-caught mice and rats for behavior trials (though I suppose in many cases, they're assessing their function as a general mammalian model rather than mouse and rat behavior specifically)?

Some of us have been working with bimacs already, but of course the cost of having available only one or a few versus all species is reducing comparative studies. One example to mention here is sucker musculature which, even today, has been described in very few species only. If we only use the specific anatomy of O. bimaculoides as "default" lets say, then you end up with a very narrow idea of how nature works. I've seen some recent work on O. vulgaris' musculature and there is enough difference between the two species to actually be able to distinguish one from the other just by looking at their sucker morphology. This fact opens up a new direction of investigations on its own.

Also, it will be hard for EU scientists to work only on bimacs, as hard it is to work in the US with Mediterranean specimens of vulgaris. By far, the biggest problem, however, will be with finding a way to work with only captive bred nautilus and squid.

As far as generalizing behavior from captive to wild population, there is a lot to be said but it is worth another thread on its own.

These are my concerns as far as using the EU Directive as a potential model. The points that I mentioned, especially working only with captive bred subjects, should not be taken lightly in favor of the benefits that such regulations provide. Overall, we can have benefits without the said costs. There are bodies such as the Cephalopod International Advisory Council (CIAC) that should have a leading role to decisions like this, rather than having government coming in and deciding for scientists, without the necessary expertise on inverts and without providing any evidence for their claims.
 
3. The argument that regulations will make our work harder is a straw man, in my opinion. Everyone who works with any animal should be doing good science - not only investigating relevant questions, but applying similarly regulatory standards to themselves de facto as would be required by IACUC rules. All of us should already be asking 'how many animals?' 'are the animals relieved from unnecessary stress?' and 'can I do this better?' as a matter of course. So having to go the extra step of getting it approved should not be particularly onerous. Regulations should only improve the science we do.

I'm with you in spirit. Additionally, I think a discussion on ethics for all animals is timely. On top of that, I politically believe that the US needs more regulators to protect consumers from bankers and other to big to fail companies with deep pockets. So I'm generally for regulation and oversight.

However, I have had a number of experiences where what actually happened and what should have happened were very different. In several of these cases animals in my care died needlessly; I have a problem with that.

Example 1: Importing cuttlefish into Canada was no problem. They have the word "fish" in their name and DFO import permits were quickly approved - seriously. This is for Sepia officinalis which might just live if it somehow escaped. . . Importing tropical octopuses into Canada was a very different beast - while also cephalopods, they do not have the word "fish" in their common name so the permit request went to go a different branch . . . which had different rules resulted in having to keep them in full Quarantine under lock and key, incinerate and report each and every one that died, kill(!!!) all animals at the end of the experiments, use an iodine bath that stained my hands and a foot bath and fill out regular paper work. This is for a tropical species of cephalopod - it and its parasites would have a very hard time in cold Canadian waters. I have and had ethical concerns with this oversight, even more so given the inconsistency between the two cephalopod species and the requirement to kill at the end.

Also, these rules are just for scientists - members of the public could buy these animals at a local pet store and legally release them into the wild. I certainly am not advocating that but making the point that as a scientist I had to jump through a lot of extra hoops.

Example 2: I once was detained for over an hour because I failed to declare an Ammonite fossil as plant or animal material as I reentered the US from Europe. I declared it, just not as a plant or animal. . . Apparently the TSA agent confused a rock for some sort of bio-hazard. . .

Example 3: Our lab at Dal was breeding scallops and putting their larvae on a space shuttle mission. One year we had 2 different animal care groups come inspect us. Like most inspections of this nature, we had advanced warning and we asked around to find out what the inspectors were looking for. The first group was from industry - we cleaned up the lab a bit but otherwise didn't do much for them. They were very impressed with our facility, our bio-filters and our healthy brood stock that produced offspring like clockwork. The second group was academic and included medical doctors and mammal people; to them "sterile" was the gold standard. So we removed than animals and bleached the tanks, pipes and everything and gave them exactly what they wanted. They were also very impressed and commented that most marine labs were much dirtier with ugly scum in their tanks while ours were so nice and clean. After that cleaning and inspection, it took 6 months before the scallops would breed again. . . which is a problem if you are trying to hit the space shuttles schedule.

Example 4: In Bermuda I had a tank of bioluminescent worms. This tanks was clearly labeled but if you looked in it, it looked more or less empty as the worms were small and lived in tubes made out of detritus. Prior to an animal care inspection, someone "cleaned" my tank and killed my animals. Death by animal care oversight strikes again!

I am not arguing against regulation - but I am suggesting that we be very careful with it. Clearly, it can be beneficial; I can point out examples of that as well. Point 3 argues that making more work is a straw man argument. I strongly disagree. In my experience oversight, especially by those w/o expertise with the animals which is typical for cephalopods, can not only make more work, it can and does occasionally kill animals needlessly - the exact opposite of the intended effect. This is especially true when non-specialists are making assessments or decisions well outside of their field or are applying standards from one field (cats, rats, marine mammals) to another where they are often completely inappropriate.

James
 
3. The argument that regulations will make our work harder is a straw man, in my opinion. Everyone who works with any animal should be doing good science - not only investigating relevant questions, but applying similarly regulatory standards to themselves de facto as would be required by IACUC rules. All of us should already be asking 'how many animals?' 'are the animals relieved from unnecessary stress?' and 'can I do this better?' as a matter of course. So having to go the extra step of getting it approved should not be particularly onerous. Regulations should only improve the science we do.

In spirit, I'm with you. Additionally, I think a discussion on ethics for all animals is timely. On top of that, I politically believe that the US needs more regulators to protect consumers from bankers and other to big to fail companies with deep pockets. So I'm generally for regulation and oversight.

However, I have had a number of experiences where what actually happened and what should have happened were very different.

Example 1: Importing cuttlefish into Canada was no problem. They have the word "fish" in their name and import permits were quickly approved - seriously. This is for Sepia officinalis which might just live if it somehow escaped. . . Importing tropical octopuses into Canada was a very different beast - while also cephalopods, they do not have the word "fish" in their common name so the permit request went to go a different branch . . . which had different rules resulted in having to keep them in full Quarantine under lock and key, incinerate and report each and every one that died, kill(!!!) all animals at the end of the experiments, use an iodine bath that stained my hands and a foot bath and fill out regular paper work. This is for a tropical species of cephalopod - it and its parasites would have a very hard time in cold Canadian waters. I have and had ethical concerns with this oversight, even more so given the inconsistency between the two cephalopod species and the requirement to kill at the end.

Example 2: I once was detained for over an hour because I failed to declare an Ammonite fossil as plant or animal material. I declared it, just not as a plant or animal. . . BECAUSE IT IS A ROCK. Apparently the agent though it was some sort of bio-hazard. . .

Example 3: Our lab at Dal was breeding scallops and putting their larvae on a space shuttle mission. One year we had 2 different animal care groups come inspect us. Like most inspections of this nature, we had advanced warning and we asked around to find out what the inspectors were looking for. The first group was from industry - we cleaned up the lab a bit but otherwise didn't do much for them. They were very impressed with our facility, our bio-filters and our healthy brood stock that produced offspring like clockwork. The second group was academic and included medical doctors and mammal people; to them "sterile" was the gold standard. So we bleached the tanks, pipes and everything and gave them exactly what they wanted. They were also very impressed and commented that most marine labs were much dirtier with scum in their tanks while ours were so nice and clean. After that cleaning and inspection, it took 6 months before the scallops would breed again. . . which is a problem if you are trying to hit the space shuttles schedule.

Example 4: In Bermuda I had a tank of bioluminescent worms. The tanks was clearly labeled but if you looked in it, it looked more or less empty as the worms were small and lived in tubes made out of detritus. Prior to an animal care inspection, someone "cleaned" my tank and killed my animals. Death by animal care oversight strikes again!

I am not arguing against regulation - but I am suggesting that we be very careful with it. Clearly, it can be beneficial. But in my experience it can also make more work and it can and does kill animals needlessly - the exact opposite of the intended effect. This is especially true when non-specialists are making assessments or decisions well outside of their field or are applying standards from one field to another where they are simply inappropriate. The reality is, very few people have knowledge of marine invertebrates and know what is and is not appropriate. Hopefully that will change.



James
 
How did I miss this thread?

I will have to agree with Rich. Why are these regulations warranted? Are there scientists and institutions doing some off the wall experiments? Or aquariums caring for their cephalopods poorly? Regulations need to be based off of sound reasoning and at this point, it appears that there is no just cause for some of the regulations being discussed.

Simply being "proactive" is not always a legitimate reason to bog down process with regulations.

I would really like to see the logic behind all of the regulations before implementing anything.

Greg
 
James, legislation can't fix stupidity!! :wink: Each of the examples you provide (my favorite is the one about the fossil....) seem more to be evidence that in the absence of any common standards of acceptable practice, individuals will act in ways that they think are best, and at times make (understandable) errors. Yes, double-standards are a problem, but one of my arguments is that regulations help prevent personal, uninformed decisions that might be harmful to the animals.

More generally:

I think it's worth noting that the primary intention of most IACUC regulations is to facilitate, not hobble, research - to ensure that research - if it's going to be done at all - is conducted on healthy, appropriately housed and properly husbanded animals. They are usually staffed primarily by scientists, veterinarians and one or two non-scientific outsiders. They are not anti-research.

As to Greg's question: Why are these regulations warranted? Are there scientists and institutions doing some off the wall experiments? Or aquariums caring for their cephalopods poorly? I personally have seen octopuses (bimacs and briareus, mature size) supposedly being used for 'learning' experiments that were housed in completely bare 12"x12"x12' plexiglass boxes, without any shelters, little room to move and under constant bright lighting with no shielding from people walking past - not overtly inhumane or cruel, but almost certainly stressful, boring and suboptimal. It is well established that for rodents, a properly enriched and appropriately appointed cage makes for not only better results, but happier animals. For octopuses, why not require the same standards? (for toxic species, different housing is of course necessary to balance the need to keep researchers safe - this is something that IACUCs regularly account for with vertebrate disease-models). If your experiment for whatever reason needs isolation, sensory deprivation, stress, pain etc., and you have valid reason for doing that to your subjects, it is the job of the impartial IACUC committee to see to it that an appropriate balance between individual welfare and overall benefits are optimised. Why argue with that?

The concern, often expressed, that the people on these committees are not well enough informed to make a correct decision on the value of the study or on what is best for the animal, can usually be overcome by in-person discussions between researchers and the panel. A related misconception I see growing in these discussions is that "The Government" somehow oversees the approval process for each study. This is, of course, not the case. The 'government' will appoint some body to devise the regulations, most likely made up of scientists at the NSF or NIH, and follow what they recommend. Not that scientists can't also do a crappy job of writing recommendations, of course... Once the recommendations are legislated, each institution uses it's own approval committee that is charged with applying those regulations.
In institutions with researchers working on inverts, those committees are going to be staffed with people familiar with invertebrate animals. It's not some random be-suited guy wearing a donkey or elephant pin, in an office in Washington, whose going to refuse to approve your application.

Note that all my focus here is on research settings, not hobbyists or private keepers. General animal welfare laws are an entirely separate beast from research animal welfare laws. (Can anyone confirm that the EU directive does not cover private owners?).

Of course, the main issue to me is that the EU has applied its directive in the absence of any data concerning pain or suffering in cephalopods. The reference they cite for evidence of 'pain sensation' is a review article that does not provide empirical evidence of this. If regulations are to be drafted, let us at least have some scientific evidence on which to ground them.
 
robyn;183277 said:
I personally have seen octopuses (bimacs and briareus, mature size) supposedly being used for 'learning' experiments that were housed in completely bare 12"x12"x12' plexiglass boxes, without any shelters, little room to move and under constant bright lighting

I have reviewed a paper on a different species of cephalopod that used somewhat similar methods. For behavioral studies such conditions are not appropriate and are very likely to negatively impact the results. It is not perfect, but we do have a peer review system that generally weeds out poor science.

Other people have different definitions of research and science. To many, research is looking something up on wikipedia. To some, science is proposing that a hypothetical squid arranged bones in a self portrait millions of years ago. . . It can't be disproved so it must be science. A dolphin show I watched made a big deal of their science as well - what do they do? They take blood samples every quarter and send them to the vet. All of these are valid definitions of research and science - but they are not what a scientist generally means by the words research and science.

Was the work mentioned above published? Did it pass peer review? Was it even submitted for publication? If you want to talk about science to scientists, peer review is the standard. I suspect the octopus "research" example you mentioned was closer to the "research" at the dolphin show I was dragged to. Perhaps I am wrong.

robyn;183277 said:
The concern, often expressed, that the people on these committees are not well enough informed to make a correct decision. . . the government. . .

I started out doing everything by the book and have learned to be concerned. I believe the examples listed above validate that concern - animals died needlessly. Yes the committee members are often scientists, good people, well meaning and experts in their field but most animal science is conducted on vertebrates which have substantially different life history and need very different life support systems. Look at any issue of animal behavior and examine the percentage of papers on invertebrates and compare it to the 95%+ of invertebrates that inhabit the planet. Well meaning scientists that work on rats can't be expected to know the basics of the nitrogen cycle or why the "ugly scum" on the tank is critical to life support. In practice, most scientists give the committee what they want (bleach the tank, incinerate the animals) rather than being the nail that sticks up and risk a confrontation which can completely shutter their research or brand them as unethically treating animals. The risk may be low, but the downside isn't.

DFO is the government in Canada. And they sent the cuttleFISH import permits requests to one group of experts and the octopus requests to another group of experts with very different results as noted above. The TSA employee I mentioned was also a govt worker. In that example I'm talking about being able to distinguish the difference between a living thing and a rock! It was the deputy director, a molecular biologist, that game the orders to clean the wet lab prior to an animal care inspection that resulted in killing my bioluminescent worms. Customs agents and Fish and Wildlife have good people working for them but often do not have the expertise to identify many of the diversity of animals that they encounter as well.

I do have serious concerns. I have leaned to have those concerns though experience. These concerns need to be part of the dialog.

In the peer review system that we have now, work is reviewed by colleagues in the same field. International colleagues that have the specialist knowledge needed to make informed decisions about the science being conducted. It isn't a perfect system, and it won't stop entertainment claiming to be science, but the level of competence and specialized knowledge is very high.
 
I suspect the octopus "research" example you mentioned was closer to the "research" at the dolphin show I was dragged to. Perhaps I am wrong.
No, it was at a university, in the lab of someone that had worked with cephalopods for quite a while, but wasn't overly concerned with welfare.

In the peer review system that we have now, work is reviewed by colleagues in the same field. International colleagues that have the specialist knowledge needed to make informed decisions about the science being conducted. It isn't a perfect system, and it won't stop entertainment claiming to be science, but the level of competence and specialized knowledge is very high.

Sure, I agree peer review is the gold standard for catching bad research. After it's been done. After the animals lived out their s****y lives in a glass box and after it was clear that the research hours and dollars and the cost of the animals' wellbeing were worthless. An IACUC's job is to see to it that doesn't happen before the research begins. I think that's better.

Having both is the ideal, in my opinion.
 

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