ML19350E551
| ML19350E551 | |
| Person / Time | |
|---|---|
| Issue date: | 06/17/1981 |
| From: | Hendrie J NRC COMMISSION (OCM) |
| To: | Dingell J HOUSE OF REP., ENERGY & COMMERCE |
| Shared Package | |
| ML19350E552 | List: |
| References | |
| NUDOCS 8106230266 | |
| Download: ML19350E551 (2) | |
Text
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NUCLEAR REGULATORY COMMISSION g
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CHAIRMAN
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J The Honorable John Dingell, Chairman Comittee on Energy and Ccmerce DE@'osr yf
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Washington, D.C.
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Dear Mr. Chairman:
This is in response to your request for the Nuclear Regulatory Commission's views on H.R. 556, a bill to develop and encourage the use of alternatives to live animals in research and testing and to establish a National Center for Alternative Research in the National Institutes of Health. The Center would include a repre-sentative from the NRC because it is an agency which conducts or sponsors research and testing involving the use of live animals.
Beginning in fiscal year 1982, the NRC would be required to devote to the development of alternative methods of
.research and testing at least 30 percent of all appropriations for research and testing involving the use of live animals. Moreover, no Federal funds could be used to sponsor or support research or testing involving the use of live animals if that research or testing would duplicate work performed by any agency. The NRC does not support this bill because it wuld impair the NRC's ability and that of other government agencies on which we rely to conduct research essential to the sound regulation of radiation hazards.
NRC conducts a relatively small amount of research (less than $2M in FY 1981) using livc animals.
These experiments are primarily focused on confirmation of the adequacy of our radiation protection regulations in are:s where specific questions have been raised. NRC has an even stronger concern, however, about the adverse impact of this bill on otner government agencies on which we rely for comprehensive radiation research information (e.g., D00, DOE, and H.H.S.).
The use of live animals in research is both difficult and expensive. Consequently, live animals are used in experiments only when required information cannot be obtained by other means.
In all other cases, well-known alternative methods of research and testing are employed.
In view of tne already limited use of live animals in radiation experiments and the availability of alternative methods of research and testing, the NRC believes that radiation research should not be included in the scope of activities of the proposed National Center for Alternative Research.
Moreover..he NRC believes that existing organizations effectively ensure coopera-tion anc coordination among federal agencies to prevent unnecessary duplication of research.
The Interagency Radiation Research Council is responsible for coordinating a comprehensive federal research program on the biological effects of ionizing radiation.
In addition, federal radiation research will be considered by the Radiation Policy Council and the Interagency Working Committee on Radioactive Waste Management. Recently, the Interagency Radiation Research Committee published a draft report on Federal Strategy for Research into the Biological Effects of Ionizing Radiation.
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'The Honorable John Dingell <
Finally, the bill is inconsistent with the scientific method to the extent that' it would preclude the use of federal funds to support research or testing on live animals if that research or testing duplicates work performed by any agency. The independent verification of experimental results.is at.the very heart of the scientific method and is essential to the vitality of scientific research. Any.
limitation on the ability to independently verify experimental results could lead to a profusion of unverified claims and an eventual loss-of confidence in all research, -Accordingly, the bill should be amended to delete any prohibition on the. funding of duplicative research.
Thank you for.this opportunity to present the NRC's views on these matters.
\\Si:ncerely, T
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Qosenb>.. Hendrie i
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