To determine which pain and distress category Subaraman's experimental rats should be placed in, the IACUC should consider the actual pain and distress that the rats will experience rather than a “reasonable potential for pain”1. Our ability to recognize pain in animals varies among species; we rely on behavioral signals as well as appearance to identify when an animal is in pain2. According to Subaraman, his research team has done this procedure hundreds of times. He testifies that when the procedure is successful, the rats will be able to walk and groom, will gain weight and will not show any abnormalities except increased sensitivity to hot and cold during specific neurological tests. The Great Eastern IACUC is basing its decision on the potential for pain or distress that may be experienced by the rats, not actual pain or distress. We believe it is more appropriate to place clinically normal rats in category D and to place those that develop clinical neuropathy in category E. Even though some rats will be placed in category D, the protocol should still include strong scientific justification for not providing pain relief to the rats placed in category E.
Because there is potential for the rats to develop clinical neuropathy, post-procedure monitoring should be detailed in the IACUC protocol. We would suggest daily monitoring of the rats for signs of pain including but not limited to signs of clinical neuropathy and more than momentary pain or distress associated with the neurological testing. Observations that could be noted include activity level, weight loss or gain, self-mutilation, guarding behaviors, aggressiveness, locomotion, writhing, piloerection, porphyrin staining, and food and water intake. The IACUC should also require Subaraman to include other ways of managing pain in the rats that develop clinical neuropathy such as using a softer bedding material.
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