What Constitutes Material Alteration of Behavior? | Lab Animal - Nature.com
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At question is what constitutes ‘material alteration’ of behavior and whether the IACUC is the one empowered to make that determination. USDA APHIS has repeatedly declined to define the operative terms ‘invasive’, ‘harm’, and ‘material alteration’, except by example, and have instead relied upon the IACUC to consider each situation and arrive at a decision. Comments from the final rule for the Field Studies definition1 provide important insights regarding this question and the intent of the regulations. USDA APHIS noted (pg 6312) statements from two commenters that “…any study has the potential to harm or materially alter the behavior of animals under study; therefore no study could be classified as a field study.” Similarly, in responding to a comment on implantation of radiotransmitters on pg 6313, USDA APHIS responded that implantation by “…perforation or incision in a manner that could cause more than short-lived pain or distress may materially alter the behavior of the animal for more than a short period of time.” In addition to the foregoing comments, the USDA APHIS Animal Care Inspection Guide2 states that “[a]nimals euthanized, killed, or trapped, and collected, such as for study or museum samples, from their natural habitat via humane euthanasia” are not to be included on the USDA annual report. Finally, the recent Wild Animals Tech Note3 makes clear that death by methods that meet the regulatory definition of euthanasia are not considered “harm”. These responses by USDA APHIS to the final rule along with language in the Inspection Guide and the Tech note make clear that the intent was not to exclude all activities with free-ranging animals, but only those that meet some undefined level of material alteration of behavior.
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