Usda pain and Distress Categories

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July 2011

USDA Pain and Distress Categories

USDA Policy #11 defines painful procedures “as any procedure that would reasonably be expected to cause more than slight or momentary pain and/or distress in a human being to which that procedure is applied.” Furthermore, USDA Policy #11 stipulates the following:

  • Individual animals that do not experience pain/distress from

testing procedures should be reported in column C.

  • Individual animals experiencing pain/distress which is alleviated with anesthetics, analgesics,

sedatives and/or tranquilizers should be reported in column D. This category

includes terminal surgery under anesthesia.

  • Individual animals in which needed anesthetics, analgesics, sedatives, and/or tranquilizers are withheld should be

reported in column E.

Note: In some cases where pain relieving drugs cannot be used the IACUC may allow the animals to be assigned to category D, if the animals are euthanized as soon as clinical signs of pain and distress are recognized.

The examples provided below are representative of the types of procedures or conditions that correlate with a particular category. The example list is not intended to be all inclusive, rather a guidance tool to assist the IACUC.

USDA Category B

USDA Category C

USDA Category D

USDA Category E

No pain or distress

Slight or momentary pain or distress
or no pain or distress

Pain or distress appropriately
relieved by analgesia,
tranquilization or anesthesia.

Unrelieved pain or distress






  1. Animals (breeders, offspring that cannot be used because of improper genotype1 and/or gender, or other animals) being maintained without any research manipulation, prior to euthanasia or transfer to another protocol.

  2. Observation of animal behavior in the wild without manipulating the animal or its environment.

  3. Physical restraint and preventative medical procedures such as routine vaccination

  4. Routine husbandry procedures

  1. Holding, weighing or transporting animals (relatively short distances under non-stressful conditions)

  2. Injections (nonirritating), blood collection or catheterization of superficial vessels

  3. Collection of body fluids or tissues post mortem

  4. Tattooing animals

  5. Ear punching of rodents

  6. Routine physical examinations

  7. Observation of animal behavior

  8. Studies, which do not result in clinical signs of pain and/or distress

  9. AVMA approved humane euthanasia procedures

  10. Routine agricultural husbandry procedures

  11. Observational studies and live trapping (traps must provide adequate shelter/food and be checked frequently to ensure survival)

  1. Potentially stressful transportation of animals that requires tranquillization

  2. Survival/terminal surgical procedures

  3. Retro-orbital blood collection under anesthesia

  4. Tail biopsy in mice > 21 days old

  5. Exposure of blood vessels for catheter implantation

  6. Exsanguination and/or perfusion under anesthesia

  7. Genetically engineered phenotype that causes pain or distress that will be alleviated.

  8. Use of Freund’s Complete Adjuvant

  9. Ocular and Skin Irritancy testing where pain and distress are relieved

  10. Any post procedural outcome resulting in evident pain, discomfort or distress such as that associated with:

•    decreased appetite/activity level
•    adverse reactions to touch
•    open skin lesions
•    abscesses
•    lameness
•    conjunctivitis
•    corneal edema or
•    photophobia

but are relieved with analgesics

11. Food or water deprivation beyond that necessary for normal presurgical preparation
12. Noxious electrical shock that is not immediately escapable.
13.Paralysis or immobility in a conscious animal

  1. Ocular or skin irritancy testing

  2. Burns or trauma

  3. Radiation sickness

  4. Toxicological or microbiological testing, cancer research or infectious disease research that requires continuation until clinical symptoms are evident or death occurs. Experiment induction of disease (i.e., Diabetes, Epilepsy, Parkinson’s, etc.) including metabolic and nutritional diseases or disease resulting from exposure to toxicants

  5. Mutants with chronic pain or debilitation which is not relieved with analgesics or by appropriate intervention.

  6. Food or water deprivation that exceeds ordinary pre-surgical preparation or is stressful to the animal

  7. Application of noxious stimuli (i.e. electrical shock) that cannot be avoided or escaped

  8. Restraint using paralyzing or immobilizing drugs without anesthesia or prolonged restraint for long periods of time (days to weeks)

  9. Exposure to abnormal or extreme environmental conditions

  10. Psychotic-like behavior suggesting a painful or distressful status whether or not resulting from a procedure

  11. Behavior or testing resulting in injury to cage mates or self

  12. Studies in which animals are allowed to die without intervention (e.g. LD50, mortality as an end-point),

  13. studies that allow endpoints that are painful or stressful (i.e., addictive drug withdrawals without treatment, pain research)

  14. Any procedures for which needed analgesics, tranquilizers, sedatives or anesthetics must be withheld for justifiable study purposes.

  15. Euthanasia by procedures not approved by the AVMA

1 If tail snips are collected to genotype the animals, Category B is not appropriate.

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