We agree that many of the standards published elsewhere in this issue of the Federal Register, would not apply to dead animals 1 . A brief analysis of the above comments indicates that not only did the original AWA not include dead animals, but one could easily view the term s use here as a misnomer. Government Printing Office, Washington DC, March 15, 1989. PHS Policy on the Care and Use of Laboratory Animals, OPRR, 1996. The use of dead animals or parts of animals in research is an area for which a clear institutional policy can help prevent serious misunderstandings and possible compliance problems.
Policy is applicable to activities involving live vertebrate animals.
Ordinarily, neither the Animal Welfare Regulations nor the PHS Policy protocol review requirements apply to dead animals in the research facility setting. Despite this, many institutions choose to require protocol review for all activities involving living or dead animals. The use of shared tissues and slaughterhouse material is an effective application of the three Rs, and is encouraged where scientifically appropriate. It is also important, however, to avoid the temptation to misuse the dead animal exemption to circumvent policy and regulation. In all cases, a paper trail is important to document that an institution has applied the appropriate standards to the acquisition, use, and disposition of animals.