Institutional Animal Care and Use Committees (IACUCs) | 337 PHS policy applies to all vertebrates, while the USDA exempts many species), an IACUC must include a veterinarian, someone who does not use animals for research, typically referred to as the non-scientist, and someone who does not work for the institution The two main duties of an IACUC are to review all proposals or protocols for use of covered species of animals, and to ensure compliance with all government regulations Policies are written in a way that allows great latitude in how these duties are discharged, for example, how many of the protocols are reviewed and discussed by the full committee, as opposed to going through an expedited review process, and how facilities are inspected by the IACUC As a result, practices vary widely depending on the size of the institution, the amount and range of animal research, and the policies set up by the individual IACUC From an ethical perspective, it must first be recognized that the whole system of IACUCs is based on the starting point that animal research is justified as long as it is carried out as well as possible, given the research goals The questions they consider are almost never of the form should we be doing research on animals but rather, given that Dr Smith is investigating X, has she shown that the study requires the use of this many animals of this species, and that she has designed the procedure to use appropriate care of the animals, including anesthetics and analgesics The two questions are not entirely separable, because Dr Smith will have to give some explanation for why animals must be used; however, the general presumption is in favor of animal research Given that starting point, there are still at least two other ethical issues raised by the practice of using IACUCs to regulate research: the scope of an IACUCs authority, and the assumption that self-regulation is the best way to bring institutions into compliance with appropriate standards for ethical research With regard to scope, it was noted above that many animals are not covered by the relevant regulations Most notably, rats and mice are not currently covered by USDA regulations, and farm animals used for production-oriented research also fall into an ambiguous category No cold-blooded species is covered by USDA regulations, and no invertebrate is covered by PHS policy Moreover, many IACUCs have adopted the policy that issues of scientific merit fall outside the scope of their decision-making process This has the effect of restricting, sometimes in significant ways, the nature of the deliberation process when trying to decide whether a particular proposal should be approved Few attempts have been made to evaluate or ground these scope restrictions with a well-formulated ethical theory The second ethical issue focuses on the fact that IACUCs are a way in which research institutions regulate themselves Some countries, for example, Sweden, have adopted systems of outside regulation Arguments that have been advanced in favor of outside regulation include a higher probability of impartial and consistent standards that might also better reflect the standards of the general public Arguments in favor of institution-based systems such as IACUCs include increased flexibility, and the fact that outside review, while feasible in localized areas with a small amount of research, would not be practical in the United States A broader perspective on the inside/outside issue might ask whether the review