DOD Animal Use: Objectives and Performance Measures Needed to Monitor Use of Alternatives for Trauma Training
Fast Facts
DOD uses live animals to train military personnel to treat battlefield injuries. DOD guidance states that alternatives will be considered and used whenever possible, if such methods produce scientifically or educationally valid or equivalent results. When animals are used, they are anesthetized to minimize pain or distress.
DOD has made efforts to consider alternatives such as training videos, mannequins, and cadavers for trauma training. However, DOD has not established measurable objectives and performance measures to track progress in reducing animal use for combat trauma training. Our recommendations address this and other issues.
A student prepares a patient for intravenous medicine during combat medic training.
Highlights
What GAO Found
The Department of Defense (DOD) has undertaken department-wide efforts to refine, reduce, and replace the use of animals for trauma training, in accordance with DOD policy, but cannot fully demonstrate the extent to which DOD has made progress in minimizing animal use. DOD has, for example, developed an incremental approach to limit the use of animals in trauma training curricula and coordinated among DOD entities and industry partners to develop training alternatives (e.g., mannequins). DOD officials told GAO that it is difficult to establish measurable objectives because they cannot predict how effective alternatives will be in the future. However, DOD does not have performance measures upon which to rely when assessing DOD's progress in reducing its use of animals. This lack of predictability does not preclude DOD from defining measurable objectives and then developing and using performance measures to monitor and evaluate its efforts. By developing specific and measurable objectives and performance measures for monitoring progress, DOD could provide greater assurance that it could assess progress in increasing its use of alternatives to live animals during trauma training.
DOD has inconsistently applied guidance for reviewing and approving trauma training protocols (see fig.).
DOD Review Process for Animal Use Protocols for Trauma Training
That is, DOD component oversight offices have taken actions that they indicated are not needed (such as conducting certain literature searches) or implemented steps that may not be applicable to trauma training (such as obtaining statistician signatures). GAO found that the component oversight offices have done so because DOD had not clarified which provisions in its guidance specifically apply to animal use protocols for trauma training or what elements should be included in trauma training protocol documentation, as distinguished from protocol documentation for other contexts. By clarifying which guidance and data elements apply to animal use protocols for trauma training, DOD will be better positioned to ensure it is consistently applying its animal use policies for trauma training, such as considering alternatives to the use of animals whenever possible.
Why GAO Did This Study
DOD uses live animals, in addition to alternatives such as training videos, mannequins and cadavers, for trauma training–that is, training for military personnel to treat acute battlefield injuries. However, the use of animals in medical education has faced long-standing scrutiny due to a continuing focus on animal welfare and continued improvement in other training methods. Various laws have addressed how animals can be used in government testing, research, and training programs and have sought to reduce this use where possible. DOD has, among other things, established a two-level review process for documents justifying animal use for trauma training, called “protocols”.
GAO was asked to review DOD's use of animals for trauma training. GAO evaluated the extent to which DOD has (1) made progress in its efforts to refine, reduce, and replace the use of animals for trauma training and (2) consistently applied guidance for reviewing and approving animal use protocols for trauma training. GAO analyzed DOD guidance and reviewed 21 fiscal year 2018–2020 animal use protocols for trauma training from the DOD component oversight offices included in GAO's review.
Recommendations
GAO makes three recommendations including that DOD develop measurable objectives, develop and use performance measures, and clarify guidance pertaining to DOD efforts to refine, reduce, and replace the use of animals in trauma training. In written comments, DOD concurred with all three of the recommendations.
Recommendations for Executive Action
| Agency Affected | Recommendation | Status |
|---|---|---|
| Department of Defense | The Secretary of Defense should ensure that the Office of the Deputy Assistant Secretary of Defense for Health Readiness Policy and Oversight, in coordination with the Under Secretary of Defense for Research and Engineering and the military services, develops objectives, in specific and measurable terms, for monitoring the department's progress in refining, reducing, and replacing animal use in trauma training. (Recommendation 1) |
DOD concurred with this recommendation. In September 2022, DOD reported that its Live Animal Use in Medical Education and Training Working Group would develop objectives, with specific and measurable terms, for monitoring progress in reducing live animal use in trauma training. The Department projected a completion date of December 2022. In February 2023, DOD reported that this working group has reviewed and considered options for monitoring live animal use and established sub-working groups to further refine efforts. DOD projected a completion date of December 2023. In January 2024, DOD provided us with information that documented that the Working Group had developed and adopted specific and measurable objectives for monitoring the department's progress. These objectives met the intent of our recommendation, which we are closing as implemented.
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| Department of Defense | Once DOD has developed measurable objectives, the Secretary of Defense should ensure that the Office of the Deputy Assistant Secretary of Defense for Health Readiness Policy and Oversight, in coordination with the Under Secretary of Defense for Research and Engineering and the military services, develops and uses performance measures—including determining which data need to be collected to monitor the department's progress in refining, reducing, and replacing animal use in trauma training. (Recommendation 2) |
DOD concurred with this recommendation. In September 2022, DOD reported that its military health system would recall the Live Animal Use-Medical Simulation Optimization sub-working group established in 2018 for an in-depth analysis of the annual data call results against simulation tool capabilities. Under this effort, the Military Departments' clinical consultants and subject matter experts will review their respective specialty training requirements for live animal use replacement eligibility, e.g., medical modeling and simulation and/or other alternatives. In February 2023, DOD reported that it has reviewed options to enhance its metrics for monitoring live animal use and the progress of its reduction. DOD projected a completion date of December 2023. In January 2024, DOD provided us with information documenting that it will collect data via data call to monitor the department's progress in refining, reducing, and replacing animal use in trauma training. We will continue to monitor the department's progress in finalizing and circulating this data call, and will update this recommendation when we receive more information.
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| Department of Defense | The Secretary of Defense should ensure that the Under Secretary of Defense for Research and Engineering ensures that the components use fully approved guidance for animal use protocols for trauma training and clarifies which protocol elements, such as literature searches and verification signatures, apply to animal use protocols for trauma training. (Recommendation 3) |
DOD, working with the DoD Laboratories, Federally Funded Research and Development Centers, and University Associated Research Centers Directorate, updated the DoD Standard Animal Use Protocol Template and provided clarification regarding regulatory needs for medical training protocols versus other research, development, testing, and evaluation animal use protocols to include verification signatures and literature searches. This action, completed in April 2022, satisfies the intent of our recommendation.
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