International Society for Transgenic Technologies Inc. (ISTT, Inc.)
Roswell Park Cancer Institute
Elm and Carlton Streets
Buffalo, NY 14263, USA
Phone: +1 (716) 845-5843
Fax: +1 (716) 845-5908
EIN: 46 3633893
September 25, 2018
Elaine Chao, Secretary of Transportation
United States Department of Transportation
1200 New Jersey Avenue, S.E.
Washington, DC 20590
Attn: Blane A. Workie, Assistant General Counsel for Aviation Enforcement Proceedings
Re: Submission in NABR v. United Airlines et al. Docket No. DOT-OST-2018-0124
Dear Madam Secretary:
We are submitting this letter to provide the Department of Transportation (DOT) with information that may be relevant to its evaluation of the above referenced complaint, which alleges that various airlines refuse to carry animals for critical biomedical research, but carry them for other purposes.
We represent the International Society for Transgenic Technologies (ISTT). ISTT is the largest organization of experts in the field of genetically modified animals worldwide. A main purpose of the society is to develop and implement technology for the creation of genetically modified animals for research purposes. Along with the National Institutes of Health (NIH), ISTT promotes responsible use of animals in research in accordance with the principles known as the 3 Rs: Replacement, Reduction, and Refinement. Our existence depends on the ability to create and distribute such organisms, including live animals, to expedite biomedical research. Transportation of animals can be necessary for sharing of resources, avoiding the unnecessary duplication of effort and animals used—principle 2, Reduction. While transportation of refrigerated or frozen sperm and embryos is possible, and is frequently preferred for those of us who work with mice, it is not always practical or feasible for transportation of other species. In fact, to demand to do so would necessitate unnecessary surgical procedures and an increase in the number of animals ultimately used for a particular research project—violating principles 2 and 3, Reduction and Refinement. The time lost and bottlenecks generated by the inability to transport such research animals would create delays in critical biomedical research, and therefore delays to treatment and cures for human diseases.
Researchers must rely on live animal research to safely develop treatments for both people and animals alike. Access to live animal subjects is required in order to conduct this revelatory work. At the same time, current laws and regulations mandate this kind of research before life-saving medicines and treatments may be approved for use in humans.
According to the complaint, many airlines refuse to transport animals for these vital scientific discoveries, although the airlines will transport the same animals for non-research purposes, such as for zoos or as pets. We believe that as long as the government requires this research, it should also enforce its laws in a way that does not undermine these essential research requirements. This arbitrary delineation by the airlines - which we understand has no transportation related purpose - threatens the progress of key research, research which could reduce or even eradicate diseases.
We urge the DOT to investigate the complaint filed by NABR and to require all airlines to eliminate policies which discriminate against animal carriage and instead base carriage solely on the fact that the purpose of the transportation of animals is for legal, legitimate, necessary and essential life-saving biomedical research. We respectfully request that DOT take these actions to ensure the continued progress of essential medical research.
Timothy Nottoli (On behalf of the Board of Directors)
Chair, Communications Committee
International Society for Transgenic Technologies