ILAR Journal Online, Volume 34(3) 1992: ILAR's Fortieth Anniversary

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ILAR Journal V34(3) 1992 [FORMERLY ILAR NEWS]
ILAR's Fortieth Anniversary

Letters

Rejoinder to "The Controlled Water Access Paradigm"
F. Barbara Orlans, Ph.D.

Dr. Orlans is a research associate at the Kennedy Institute of Ethics, Georgetown University, Washington, D.C.

My article in ILAR News described the reasoning behind a decision of an Institutional Animal Care and Use Committee (IACUC) to disapprove a protocol involving rhesus monkeys, Macaca mulatta, who were deprived of water for 22 hours a day for 5 out of 7 days a week on a recurring cycle [ILAR News 33(3):48-52, 1991]. In their response, Desimone, Olson, and Erickson claim that such a procedure is "permitted by the regulations that govern animal research, is necessary in many cases, and is humane'' (p. 29). Each of these three assertions is fallacious.

1. Regarding official policies, the respondents substantiate their claim that repeated cycles of 22 hours of water deprivation is "permitted by the [US] regulations" (p. 29) by citing a report from an NIH workshop. It is preposterous to suggest that a report from an NIH workshop comprises "regulations." This document explicitly disavows any regulatory intent: "[this report] does not establish NIH policy nor does it reflect a change in official animal care and use guidelines" (Van Sluyters and Oberdorfer, 1991, p. 9). Further, the introduction emphasizes that this publication is distributed for "informational purposes only."

Desimone et al. also argue that the Animal Welfare Act and the mandated policy of the Public Health Service "do not prohibit" (p. 27) this paradigm of water deprivation as an inducement to do a task. These policies do not address the issue, which is quite a different thing. The language of national policies is commonly phrased in general terms, not specifics. The policies provide general outlines of what is required.

There are two provisions of U.S. national policy that are pertinent and they offer no support for the position taken by Desimone et al. First, the Public Health Service Policy on the Humane Care and Use of Laboratory Animals states that "...investigators should consider that procedures that cause pain or distress in human beings may cause pain or distress in other animals." (PHS, 1986, p. 27). Second, national policy requires that "Procedures with animals will avoid or minimize discomfort, distress, and pain to the animals, consistent with sound research design" (PHS, 1986, p.7).

The respondents cite two sources, one Canadian and one American, that acknowledge controlled water access as a procedure that is in current use: One is authored by a group of Canadian psychologists and appears in a piece entitled "Addendum: The Use of Animals in Psychology,'' and the other is the aforementioned NIH workshop report. Their quote from the Canadian source is indeed included in the Canadian Council on Animal Care's Guide to the Care and Use of Experimental Animals but the passage quoted is not strictly speaking a part of any Canadian "policy." The addendum's intent is to explain why animals are used at all in psychology research, to emphasize investigator responsibility, and to describe some current procedures. It precedes a section called "Guidelines" which does establish official policy for Canadian psychologists. Neither the Canadian nor the American sources quoted by Desimone et al. provide guidance on how long a period or frequency of water deprivation is permissible or other constraints on the use of this paradigm. Statements that describe current practices but that do not indicate what limits should be set do not qualify as guidance on these matters. They are merely acknowledgements that such practices exist.

A relevant passage of the Canadian psychologists' "Guidelines" not mentioned by Desimone et al. states: "Procedures subjecting animals to pain, stress, privation, or death should be used only when an acceptable alternative procedure is unavailable" (CCAC, 1980).

Desimone et al. are correct in pointing out that the guidelines of the U.K.'s Biological Council appeared out of context in my article--these guidelines do not address the issue of water deprivation as an experimental method to induce an animal to do a task. I apologize for the error.

2. Regarding the necessity of prolonged water deprivation, in one paragraph the respondents assert that it is necessary in many cases without providing any evidence for this statement. Elsewhere they say they would need to know more about details of the behavioral task and other aspects of the protocol before evaluating if water restriction is necessary. In short, nowhere do they provide any proof of necessity nor do they face the question that, if water deprivation is to be used at all, just how much deprivation is necessary? Instead of 22 hours could lesser periods of time by substituted--21 V2 hours or 18 hours for instance? Or perhaps no more than 12 hours would be appropriate (bringing the protocol into conformity with the 1988 policy of the New York Academy of Sciences (New York Academy of Sciences, 1988), which specifically addresses the paradigm of water deprivation). The onus is on the investigator to show that the proposed period of water deprivation rather than lesser periods are necessary. The onus is not on the committee to produce counter evidence that a proposed procedure is harmful.

3. Regarding animal welfare, Desimone et al. state that involving monkeys in performing tasks for fluid rewards "may actually improve their psychological well-being (p. 29)." They back up this statement by saying that, among other things, "the change in environment ... [is] enriching" (p. 29) for the experimental subjects. The experimental protocol I described involved placing the monkeys in restraint chairs. Is this enriching? The respondents further say that monkeys in the wild may be exposed to periods of restricted water availability and that obtaining water drop by drop also mirrors conditions encountered in the wild. But because animals do indeed suffer certain hardships such as drought (and one might add exposure to predators, and other harms) in the wild, this does not provide justification to use such hardships as a baseline for standards of animal maintenance in captivity. From an animal welfare standpoint, there is a moral obligation to use the best possible methods of maintaining animals in captivity. It is a distortion to present potentially life-threatening hardships as improving the psychological well being of captive primates that have no control over the conditions of their environment--no options--and no means of escape from human-imposed hardships.

A major issue to be addressed is whether or not the same scientific objective can be accomplished by imposing lesser harms on the animal. In fact, there is both an ethical and legal obligation to select procedures that do the least harm to the animal that are commensurate with the scientific objectives. As argued in my original piece, the preferred route is to use the alternative of rewards of high choice foods and drinks that are not part of the monkeys' normal diet (mandarin oranges, yogurt, Gatorade, or malted milk) rather than the punishment of prolonged thirst.

There was no mislabeling of my original piece, as Desimone et al. claim. My article incorporates opinions and judgments of a committee of the type that must be rendered whenever such a committee confronts an ethical issue. This case described how a committee conscientiously addressed the issues and came to a decision. In writing up the piece, certain additions were made (thus making it a "composite"); included were suggestions of relevant policies made by members of IACUCs that had faced decisions on water deprivation that they knew about and at that time I did not. There is nothing unusual in my approach in writing this article. Case studies are an important pedagogic tool, and are used extensively in bioethics, medicine, law, and business. Composite cases (often done in order to maintain confidentiality and also for other reasons) are frequently used, as reference to collections of case studies will show.

The respondents may be commended for opening up this discussion further since the objective of presenting a case study, as I did, is to make investigators and others aware of experimental procedures that require moral reflection, judgment, and decision. I trust that this exchange will stimulate continued discussion of the issues raised.

References

CCAC. 1980. Guidelines for the use of animals in research and instruction in psychology, P. I 18 in Guide to the Care and Use of Experimental Animals. Ontario, Canada: Canadian Council on Animal Care.

New York Academy of Sciences. 1988. Interdisciplinary Principles and Guidelines for the Use of Animals in Research, Testing, and Education. New York: New York Academy of Sciences. P. 8.

PHS (Public Health Service). 1986. Policy on Humane Care and Use of Laboratory Animals. Washington, D.C.: U.S. Department of Health and Human Services.

Van Sluyters, R. C., and M. D. Oberdorfer, eds. 1991. Preparation and Maintenance of Higher Mammals During Neuroscience Experiments. Report of a National Institutes of Health Workshop. U.S. Department of Health and Human Services (NIH Publication 91-3207).